There is a foreign tax credit limitation basket for global intangible low-taxed income (GILTI) (other than passive category income) (referred to as section 951A category income).
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IRC 951A. Acting as a minimum tax on foreign profits, under the Tax Cuts and Jobs Act global intangible low-taxed income provision, each U.S. shareholder of a ...
Section 951A(a), the acronym for global intangible low-taxed income. GILTI is attributable, in whole or in part, to insurance income (as defined in. Section ...
Sec. 951A. Global Intangible Low-Taxed Income Included In Gross Income Of United States Shareholders · Pub. L. 115-97 · BACKGROUND NOTES · EFFECTIVE DATE.
26 U.S. Code § 951A - Global intangible low-taxed income included in gross income of United States shareholders. U.S. Code.
(A) Subpart F income limited to current earnings and profits. For purposes of subsection (a), the subpart. F income of any controlled foreign corpora- tion ...
A person who is a U.S. shareholder of any controlled foreign corporation (CFC) is required to include its global intangible low-taxed income (GILTI) in ...
Oct 10, 2018 · Section 951A(a) provides that a U.S. shareholder of any CFC for a taxable year must include in gross income its GILTI for that year. A GILTI ...
Jun 9, 2021 · IRC 951A, which contains the global intangible low-taxed income (“GILTI”) rules, was added to the Code by the Tax Cuts and Jobs Act.
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Posted: Aug 5, 2021
Posted: Aug 5, 2021