Date: 2019-06-21
Links to Federal Register: HTML, PDF
(Proposed Regulation: REG-105600-18 HTML, PDF)
Document Number: 2019-12437, RIN: 1545-BO54
Action: Final and temporary regulations.
Abstract: This document contains final regulations that provide guidance to determine the amount of global intangible low-taxed income included in the gross income of certain United States shareholders of foreign corporations, including United States shareholders that are members of a consolidated group. This document also contains final regulations relating to the determination of a United States shareholder's pro rata share of a controlled foreign corporation's subpart F income included in the shareholder's gross income, as well as certain reporting requirements relating to inclusions of subpart F income and global intangible low-taxed income. Finally, this document contains final regulations relating to certain foreign tax credit provisions applicable to persons that directly or indirectly own stock in foreign corporations.
| Notable phrases | Frequency |
|---|---|
| tested income | 633 |
| pro rata share | 303 |
| subpart F income | 215 |
| gross tested income | 194 |
| tested income CFC | 172 |
| CFC inclusion year | 166 |
| specified tangible property | 154 |
| United States shareholder | 123 |
| GILTI inclusion amount | 122 |
| U.S. shareholder inclusion year | 77 |
| hypothetical distribution | 76 |
| tested loss CFC | 74 |
| qualified business asset investment | 73 |
| tested interest expense | 70 |
| allocated and apportioned | 70 |
| tested interest income | 69 |
| specified interest expense | 63 |
| foreign tax credit | 63 |
| deemed tangible income return | 51 |
| basis in the stock | 47 |
| net operating loss | 35 |
| net CFC tested income | 34 |
| Reg. Cites | Frequency |
|---|---|
| 1.951A-2(c)(3) | 41 |
| 1.951A-2(c)(5) | 37 |
| 1.952-2 | 15 |
| 1.1502-51 | 14 |
| 1.861-12(c)(2)(i)(B)(1)(ii) | 12 |
| 1.951A-3(e)(3)(ii) | 12 |
| 1.965-2(f)(2)(i) | 12 |
| 1.951A-7 | 11 |
| 1.951-1(b)(1)(i) | 10 |
| 1.951A-1(c)(3)(iii) | 10 |
| 1.965-7(e)(2)(ii)(B) | 10 |
| 1.78-1 | 9 |
| 1.951A-3 | 9 |
| 1.951A-3(b) | 8 |
| 1.954-1(d)(6) | 8 |
| 1.951A-2 | 8 |
| 1.951A-1 | 7 |
| 1.951-1 | 7 |
| 1.951A-6 | 7 |
| 1.861-12 | 6 |
| Sec. Cites | Frequency |
|---|---|
| 951A | 146 |
| 78 | 45 |
| 965(n) | 42 |
| 958(a) | 36 |
| 704(b) | 32 |
| 954(b)(4) | 29 |
| 965(a) | 28 |
| 952(c)(1)(A) | 28 |
| 952(c)(2) | 25 |
| 952(c) | 24 |
| 965 | 22 |
| 951A(c)(2)(A)(i)(II) | 21 |
| 958(a) | 20 |
| 965(c) | 19 |
| 904 | 18 |
| 951(a)(2)(B) | 17 |
| 951(a)(2)(A) | 17 |
| 951(a)(1)(A) | 16 |
| 951A(d)(3) | 16 |
Statistics
Number of pages: 83, words: 99,465, sentences: 3,206
Average words per sentence: 31