# Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits
> **IRS** · Final and temporary regulations. · Published 2019-06-21 · Effective 2019-06-21 · 84 FR 29288
## Document
- **Document number:** 2019-12437
- **Category:** other
- **Sub-agency:** IRS
- **Federal Register citation:** 84 FR 29288
- **CFR reference:** 26 CFR 1
- **Publication date:** 2019-06-21
- **Effective date:** 2019-06-21
- **Treasury docket:** TD 9866
## Abstract

This document contains final regulations that provide guidance to determine the amount of global intangible low-taxed income included in the gross income of certain United States shareholders of foreign corporations, including United States shareholders that are members of a consolidated group. This document also contains final regulations relating to the determination of a United States shareholder's pro rata share of a controlled foreign corporation's subpart F income included in the shareholder's gross income, as well as certain reporting requirements relating to inclusions of subpart F income and global intangible low-taxed income. Finally, this document contains final regulations relating to certain foreign tax credit provisions applicable to persons that directly or indirectly own stock in foreign corporations.

## Source
- [Federal Register document](https://www.federalregister.gov/documents/2019/06/21/2019-12437/guidance-related-to-section-951a-global-intangible-low-taxed-income-and-certain-guidance-related-to)
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