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Layla Asali Comments on CFC Group Definition in IRS Final Regs in Tax Notes

Subtitle
"IRS Defends Broader GILTI High-Tax CFC Group Definition"

Tax Notes

Layla Asali commented on final Treasury Regulations regarding the GILTI high-tax exclusion election at the ABA Philadelphia Tax Conference. Asali discussed the consistency rules for CFC groups with government officials and observed that the definition of a CFC group is broader than what is usually seen in other contexts, such as the 80 percent threshold used in the foreign tax credit deconsolidation limitation rules.