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Yes, the proposed GILTI regulations didn’t answer some of the tough questions, particularly those surrounding the calculation of foreign tax credits. But the regulations do address other critical issues and suggests the general approach of Treasury and the Internal Revenue Service to drafting regulations under the 2017 tax act (Act). (Notice of Proposed Rulemaking, Guidance Related to Section 951A (Global Intangible Low-Taxed Income) 83 Fed. Reg. 51,072 (Oct.
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