U.S. Chamber Comments on REG-127732-19: Guidance under Section 954(b)(4) Regarding Income Subject to a High Rate of Foreign Tax

On September 16, 2020, the U.S. Chamber delivered these comments to the I.R.S. and Treasury on REG-127732-19, proposed regulations under the subpart F income and global intangible low-taxed income provisions of the Internal Revenue Code regarding the treatment of certain income that is subject to a high rate of foreign tax, as well as proposed regulations under the information reporting provisions for foreign corporations to facilitate the administration of certain rules in the proposed regulations, as published in the Federal Register on July 23, 2020.