Final Regs Adopt Single-Entity Approach for CFC Income Inclusion
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Final Regs Adopt Single-Entity Approach for CFC Income Inclusion
US Treasury and the IRS have issued final regulations to treat a consolidated group that includes controlled foreign corporations as a single entity when calculating the group’s required foreign income inclusions by addressing how they must treat distributions of previously taxed earnings and profits under section 959(b) to upper-tier CFCs within the group when calculating the amount that must be included in gross income under subpart F and the global intangible low-taxed income regime.
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