United States Government Publishing Office publisher pbl distributor dst United States National Archives and Records Administration Office of the Federal Register author aut Government Organization text government publication eng FR Regulatory Information 2019_register executive 2019-06-21 article Part II Rules and Regulations D09002ee1c7d1435b D09002ee1c7d145dc United States Department of the Treasury originator org United States Government Agency or Subagency United States Internal Revenue Service originator org United States Government Agency or Subagency This document contains final regulations 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, including United States shareholders that are members of a consolidated group. This document also contains final regulations relating to the determination of a United States shareholder's pro rata share of a controlled foreign corporation's subpart F income included in the shareholder's gross income, as well as certain reporting requirements relating to inclusions of subpart F income and global intangible low-taxed income. Finally, this document contains final regulations relating to certain foreign tax credit provisions applicable to persons that directly or indirectly own stock in foreign corporations. 84 FR 29288 https://www.govinfo.gov/app/details/FR-2019-06-21/2019-12437 2019-12437 fr21jn19-30 RIN 1545-BO54 RIN 1545-BO62 4830-01-P TD 9866 https://www.govinfo.gov/app/details/FR-2019-06-21/2019-12437 https://www.govinfo.gov/content/pkg/FR-2019-06-21/html/2019-12437.htm https://www.govinfo.gov/content/pkg/FR-2019-06-21/pdf/2019-12437.pdf Income Taxes Reporting and Recordkeeping Requirements 83 p. 29288 29370 84 FR 29288 Title 26 Part 1 26 CFR Part 1 RIN 1545-BO54 RIN 1545-BO62 Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits; Federal Register Vol. 84, Issue RULE 2019-12437 II DEPARTMENT OF THE TREASURY Internal Revenue Service 2019-06-21 TD 9866 4830-01-P 2019-12437 Final and temporary regulations.

This document contains final regulations 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, including United States shareholders that are members of a consolidated group. This document also contains final regulations relating to the determination of a United States shareholder's pro rata share of a controlled foreign corporation's subpart F income included in the shareholder's gross income, as well as certain reporting requirements relating to inclusions of subpart F income and global intangible low-taxed income. Finally, this document contains final regulations relating to certain foreign tax credit provisions applicable to persons that directly or indirectly own stock in foreign corporations.

Effective date: These regulations are effective on June 21, 2019. Concerning the regulations Sec. Sec. 1.951-1, 1.951A-0 through 1.951A-7, 1.6038-2, and 1.6038-5, Jorge M. Oben at (202) 317-6934; concerning the regulations Sec. Sec. 1.951A- 1(e) and 1.951A-3(g), Jennifer N. Keeney at (202) 317-5045; concerning the regulations Sec. Sec. 1.1502-12, 1.1502-32, and 1.1502-51, Katherine H. Zhang at (202) 317-6848 or Kevin M. Jacobs at (202) 317- 5332; concerning the regulations Sec. Sec. 1.78-1, 1.861-12, 1.861- 12T, and 1.965-7, Karen J. Cate at (202) 317-6936 (not toll free numbers). Income Taxes Reporting and Recordkeeping Requirements Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits , http://www.irs.gov https://apps.irs.gov/app/picklist/list/draftTaxForms.html https://www.irs.gov/pub/irs-pdf/i5471.pdf https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201805-1545-019 https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201806-1545-014 https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201808-1545-031 https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201811-1545-003 www.regulations.gov Vol. 84, no. 120 Office of the Federal Register, National Archives and Records Administration 2019-06-21 continuing daily deposited born digital 352 p. Table of Contents: AE 2.7: GS 4.107: AE 2.106: KF70.A2 https://www.govinfo.gov/app/details/FR-2019-06-21 P0b002ee1a174ff71 0097-6326 0042-1219 0364-1406 769-004-00000-9 000582072 f:fr21jn19 https://www.govinfo.gov/app/details/FR-2019-06-21 https://www.govinfo.gov/content/pkg/FR-2019-06-21/pdf/FR-2019-06-21.pdf https://www.govinfo.gov/content/pkg/FR-2019-06-21/xml/FR-2019-06-21.xml fdlp 29029 29370 DGPO 2019-06-21 2024-05-31 FR-2019-06-21 machine generated eng FR FR-2019-06-21 84 120