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federal_register: 2020-15351

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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts regulation_id_numbers
2020-15351 Guidance Under Sections 951A and 954 Regarding Income Subject to a High Rate of Foreign Tax Rule This document contains final regulations under the global intangible low-taxed income and subpart F income provisions of the Internal Revenue Code regarding the treatment of income that is subject to a high rate of foreign tax. The final regulations affect United States shareholders of foreign corporations. This guidance relates to changes made to the applicable law by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. 2020-07-23 2020 7 https://www.federalregister.gov/documents/2020/07/23/2020-15351/guidance-under-sections-951a-and-954-regarding-income-subject-to-a-high-rate-of-foreign-tax https://www.govinfo.gov/content/pkg/FR-2020-07-23/pdf/2020-15351.pdf Treasury Department; Internal Revenue Service 497,254 This document contains final regulations under the global intangible low-taxed income and subpart F income provisions of the Internal Revenue Code regarding the treatment of income that is subject to a high rate of foreign tax. The final regulations... 1545-BP15

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