The U.S. Treasury Department Issued Proposed Regulations Allowing Individual U.S. Shareholders Making 962 Election The Section 250 Deduction with Respect to Their GILTI.

The U.S. Department of Treasury issued much awaited proposed regulations (REG-104464-18) under Internal Revenue Code (the “Code”) section 250 to provide further guidance to determine the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI).