Date: 2020-07-23
Links to Federal Register: HTML, PDF
Document Number: 2020-15349, RIN: 1545-BP62
Action: Notice of proposed rulemaking.
Abstract: This document contains proposed regulations under the subpart F income and global intangible low-taxed income provisions of the Internal Revenue Code regarding the treatment of certain income that is subject to a high rate of foreign tax. This document also contains proposed regulations under the information reporting provisions for foreign corporations to facilitate the administration of certain rules in the proposed regulations. The proposed regulations would affect United States shareholders of controlled foreign corporations.
| Notable phrases | Frequency |
|---|---|
| tested unit | 229 |
| controlled foreign corporation(s) | 94 |
| tentative net item | 64 |
| applicable financial statement | 62 |
| foreign base company income | 42 |
| allocated and apportioned | 41 |
| CFC inclusion year | 35 |
| subpart F high-tax exception | 32 |
| GILTI high-tax exclusion | 28 |
| United States shareholder(s) | 28 |
| properly reflected on the applicable financial statement | 24 |
| subpart F income | 22 |
| foreign income taxes paid or accrued | 18 |
| gross foreign base company income | 15 |
| rate of foreign tax | 14 |
| earnings and profits | 13 |
| attributable to a tested unit | 13 |
| treated as a single tested unit | 10 |
| effective rate of foreign tax | 9 |
| insurance income of (a|the) controlled foreign corporation | 8 |
| applicable financial statement of the tested unit | 7 |
| high-tax exception of section 954(b)(4) | 6 |
| exclusion, exemption, or other similar relief | 5 |
| subject to an effective foreign tax | 5 |
| gross income of the controlled foreign corporation | 5 |
| gross income attributable to a tested unit | 4 |
| reflected on the books and records | 4 |
| give rise to a taxable presence under the tax law of the foreign country | 2 |
| Reg. Cites | Frequency |
|---|---|
| 1.6038-2(f)(19) | 15 |
| 1.954-1(d)(6)(i)(A)(1) | 13 |
| 1.954-1(d)(6)(vii)(A) | 8 |
| 1.951A-2(c)(1)(iii) | 8 |
| 1.954-1 | 8 |
| 1.954-1(d) | 7 |
| 1.960-1(d)(3) | 6 |
| 1.954-1(d)(6) | 6 |
| 1.952-1(f)(2)(ii) | 5 |
| 1.861-8 | 4 |
| 1.951A-2 | 4 |
| 1.904-6(b)(2) | 4 |
| 1.952-1(f)(4) | 3 |
| 1.904-4(f)(2)(vi) | 3 |
| 1.954-1(d)(3)(i) | 3 |
| 1.1502-77(a) | 3 |
| 1.952-1(c) | 2 |
| 1.954-1(a)(2)(i) | 2 |
| 1.954-1(a)(5) | 2 |
| 1.6038-2 | 2 |
| Sec. Cites | Frequency |
|---|---|
| 954(b)(4) | 45 |
| 951 | 10 |
| 951A | 9 |
| 381(a) | 9 |
| 952(c)(2) | 8 |
| 951A(c)(2)(A)(i)(III) | 8 |
| 954(b)(5) | 5 |
| 952(c)(1) | 5 |
| 953 | 5 |
| 958(a) | 5 |
| 11 | 4 |
| 861 | 4 |
| 952(c)(1)(A) | 3 |
| 952(b) | 3 |
| 954(b)(3)(A) | 3 |
| 954(b)(3)(B) | 3 |
| 904 | 3 |
| 952(c) | 2 |
| 954(b) | 2 |
Statistics
Number of pages: 26, words: 28,460, sentences: 889
Average words per sentence: 32