WebNov 1, 2024 · The high-tax exclusion applies only if the GILTI was subject to foreign income tax at an effective rate greater than 18.9% (90% of the highest U.S. corporate tax rate, which is 21%). This threshold is unchanged from the proposed regulations. The effective foreign tax rate for purposes of the high-tax exclusion is calculated on a tested-unit basis. Webtion and philosophical underpinnings of SEN and inclusion across a number of countries, and outlines the current educational practices, legislation and ... Hodkinson-3827-Ch-06.qxp 4/8/2009 4:25 PM Page 90. Reader Reflection The UN is an international organisation that aims to facilitate co-operation in international law, international security ...
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