TAX 9869 Lecture Notes - Lecture 55: Tax Treaty, Qualified Dividend, Ordinary Income
Document Summary
Treasury released final regs on gilti high tax exception. In conjunction with that, treasury issued proposed regs on subpart f high tax exception. Subpart f high tax exception: tp can elect to exclude from subpart f income any subpart. Works on an item by item basis. Tp can choose to apply the high tax exception for one item of sub f income and perhaps. Doesn"t necessarily go by cfc in its entirety; can look @ diff sub f items- this is high tax, not for other items exclude it. Difference we have w/ the gilti high tax exception was Looking @ tested income of diff biz of cfc and then applying an etr on that. Important both for sub f and gilti to know that it is an etr test. Ex: uk has corp tax rate of 19% (higher than 18. 9) or netherlands/luxembourg.
