Proposed and Final Regulations were issued addressing Section 163(j) interest.
Links are attached for reference
Pursuant to Final and Proposed Regulations recently published, the high-tax exception would be a “unitary” election for both GILTI and Subpart F.
The election is made annually, and can apply retroactively to post-TCJA years.
In summary, Treasury has adopted some taxpayer comments favorably, while delivering an unexpected result in their guidance.
EY’s Alert provides additional background, with links to the Regulations.
The Final Reg’s for Section 250, used in FDII and GILTI calculations, have been finalized. These Reg’s are now undergoing analyses in trying to understand the complexities and nuances. Some highlights include:
The Final Reg’s provided additional clarity, although a taxpayer will have to consider if the Proposed Reg’s or Final Reg’s will be favorable for tax years prior to 2021.
EY’s Tax Alert provides additional details, as referenced.
KPMG’s initial observations of the final and proposed BEAT regulations are attached for reference:
KPMG has provided a quick turnaround on the final and proposed Foreign Tax Credit regulations, linked for reference.
Final and proposed Regulations were issued with respect to the Foreign Tax Credit and BEAT. Noting this regulation package collectively amounts to over 650 pages, it will require time and attention to webcasts, etc. to fully understand the breadth of these rules, especially as they may pertain to 2018 and/or 2019.