Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits

摘要

This document contains corrections to Treasury Decision 9866, which was published in the Federal Register on Friday, June 21, 2019. Treasury Decision 9866 contained final regulations under section 951A of the Internal Revenue Code that provide guidance to determine the amount of global intangible low-taxed income included in the gross income of certain United States shareholders of foreign corporations.