The Resource Domestic partnerships and GILTI : Treasury's novel approach to this quagmire

Domestic partnerships and GILTI : Treasury's novel approach to this quagmire

Label
Domestic partnerships and GILTI : Treasury's novel approach to this quagmire
Title
Domestic partnerships and GILTI : Treasury's novel approach to this quagmire
Creator
Subject
Language
eng
Summary
U.S. Treasury and the IRS recently issued Proposed Regulations (REG-104390-18) implementing Section 951A (Global intangible low-taxed income included in gross income of United States shareholders). The GILTI Proposed Regulations provide guidance on various operational and computational issues related to determining a U.S. shareholder's global intangible low-taxed income (GILTI) inclusion amount. This article focuses on one of the provisions in the GILTI Proposed Regulations, which is a hybrid-type approach in addressing the treatment of domestic partnerships and their partners under Section 951A
Citation source
In: Journal of international taxation. - New York. - Vol. 30 (2019), no. 1 ; p. 40-57
http://library.link/vocab/creatorName
  • Calianno, J.M
  • Dokko, S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • GILTI
  • partnership
Label
Domestic partnerships and GILTI : Treasury's novel approach to this quagmire
Instantiates
Publication
Label
Domestic partnerships and GILTI : Treasury's novel approach to this quagmire
Publication

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