Proposed regulations under GILTI provisions released in Federal Register
Proposed regulations under GILTI provisions released
The U.S. Treasury Department and IRS this afternoon released for publication in the Federal Register proposed regulations (REG-104390-18) relating to the “global intangible low-taxed income” (GILTI) provisions under the new U.S. tax law.
Read the proposed regulations [PDF 389 KB] (40 pages) as officially released for publication in the Federal Register.
Treasury and the IRS on September 13, 2018, released a version of these proposed regulations, and with that release, noted that the proposed regulations had been submitted to the Federal Register for publication; that such publication was pending; and that the version of the proposed regulations released on September 13 “… may vary slightly from the published document if minor editorial changes are made during the [Federal Register] review process. The document published in the Federal Register will be the official document.”
Treasury and the IRS have requested comments on these proposed regulations. Comments and requests for a public hearing must be received by a date that is 60 days after the date when these regulations will appear in the Federal Register, which is scheduled for October 10, 2018.
Now that the proposed regulations have been released for publication in the Federal Register, a question is whether any changes were made.
Read a computer-generated document [PDF 3.8 MB] (an unofficial document produced by KPMG) that compares the version of the proposed regulations released on September 13, 2018, with the version of the proposed regulations released today for publication in the Federal Register. This document is intended to show what changes, if any, have been made to the proposed regulations prior to publication in the Federal Register. It has not been reviewed for accuracy.
Legend: Omitted text is shown as stricken, new text is indicated by the blue "symbol," and replaced text is highlighted in orange.
© 2023 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
For more detail about the structure of the KPMG global organization please visit https://kpmg.com/governance.
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.