The IRS on Tuesday issued guidance on accounting policy changes made by certain overseas companies.
The Guidelines (Rev. Proc. 2021-26) apply to controlled foreign companies and expand the final rules enacted in 2019 for Section 951A that deal with Global Low Intangible Tax Income (GILTI) – a new category of foreign income created in 2017 became tax law.
- The guidance also extends the use of automatic consent for changes in the depreciation method and addresses, among other things, audit protection.
- Controlled overseas corporations are companies that are more than 50% owned by US shareholders who own 10% or more of the …