GILTI and Subpart F High Tax Exception Regulations (New Guidance Pt. 1) Skip to main content

Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications

Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications

Overview



Video – GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications webinar, part of McDermott’s 2020 Virtual Tax Forum programming (runtime: 1h12m)

The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact pattern.

During this program, we illustrated some of the benefits and drawbacks that may arise from these regulations, and provided practical considerations that will help you navigate the decision as to whether to make an election to apply the global intangible low-taxed income (GILTI) high-tax exclusion. We discussed:

  • Key considerations when deciding to make the election to apply the GILTI high-tax exclusion
  • Who is most likely to benefit from making this election
  • Main reasons to not elect to apply the GILTI high-tax exclusion
  • Traps for the unwary in the proposed subpart F high-tax exclusion regulations

ADDITIONAL UPCOMING VIRTUAL TAX FORUM PROGRAMMING
Stay tuned for our additional upcoming programming. Registration details forthcoming.

Questions? Contact Callie Forkenbrock.

Dig Deeper

Orlando, FL / Speaking Engagements / November 5 – 7, 2025

The Bank & Capital Markets Tax Institute 2025

San Francisco, CA / Speaking Engagements / October 26 – 29, 2025

TEI's 2025 Annual Conference

Nashville, TN / Speaking Engagements / October 27 – 29, 2025

32nd Annual Paul J. Hartman State and Local Tax Forum

San Francisco, CA / Speaking Engagements / October 26 – 29, 2025

TEI's 80th Annual Conference

Lisbon, Portugal / Sponsored Events / October 5-9, 2025

IFA 2025 Congress

Get In Touch