Treasury and IRS Issue Accounting Method Change Guidance for Foreign Corporations

Summary

Treasury and IRS issued Revenue Procedure 2021-26 regarding accounting method changes made on behalf of controlled foreign corporations (CFCs). The guidance expands on final regulations issued in 2019 implementing Internal Revenue Code Sec. 951A, regarding global intangible low-taxed income (GILTI) inclusions and reporting. GILTI was established under the Tax Cuts and Jobs Act (TCJA) and applies to tax years beginning after December 31, 2017.