RILA Letter to Request for Guidance on Expense Apportionment


The Retail Industry Leaders Association (“RILA”) respectfully requests that the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issue guidance indicating that, for purposes of the foreign tax credit limitation under section 904(a), indirect expenses (such as interest and stewardship) are not apportioned to any amount includible in gross income of a United States shareholder as Global Intangible Low-Taxed income (“GILTI”) under section 951A of the Internal Revenue Code, as amended by P.L. 115-97 (the “Code”).

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