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Treasury & Taxation

Proposed Regs Favorably Affecting Foreign Currency Hedging Transactions

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July 27, 2018

The Tax Cuts and Jobs Act has changed the way companies use the GILTI regime, which will now require non-Subpart F income to be taxed currently but at a lower rate than regular income. 

US shareholders of controlled foreign corporations (CFCs) have to include certain forms of passive income in their taxable income.

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