GILTI as charged (3rd booking): the 2020 high-tax exception regs
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Elizabeth Nelson (ITS Partner in PwC's Washington National Tax Services) discuss the recently-issued final and proposed high-tax exception regulations under the global intangible low-taxed income (GILTI) and subpart F income regimes. Doug and Elizabeth unpack: the background and history of the high-tax exception; the similarities and differences between the previously proposed high-tax exception regulations and the final high...