Regulatory Comment Letter

Comments on GILTI Expense Allocation Rules

Regulatory Comment Letter

Comments on GILTI Expense Allocation Rules


These comments were submitted by trade associations requesting a regulatory modification to the Global Intangible Low-Taxed Income (GILTI) expense allocation rules. Such modification would, consistent with Congressional intent, ensure that GILTI would not apply to taxpayers with foreign tax rates of at least 13.125 percent.