U.S. IRS Issues Correction to Proposed Rules for Determining Stock Ownership for GILTI

On 2 August 2019, a correction to a notice of proposed rulemaking issued by the U.S. IRS and Treasury was published in the Federal Register. The correction concerns the Guidance under Section 958 (Rules for Determining Stock Ownership) and Section 951A (Global Intangible Low-Taxed Income), which was published on 21 June 2019.

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Background

The proposed regulations that are the subject of this correction are under section 951A of the Internal Revenue Code.

Need for Correction

As pub…