On November 26, 2018, TEI filed comments with the United States Department of the Treasury and Internal Revenue Service regarding proposed regulations issued under section 951A. New section 951A, included in the Internal Revenue Code by the Tax Cuts & Jobs Act enacted in late 2017, implements requires U.S. shareholders of controlled foreign corporations to include in their income their global intangible low-taxed income, or “GILTI”. The Institute’s comments focused on the practical aspects of the proposed regulations, including the determination of the qualified business asset investment, used tested losses, and the anti-abuse rule. TEI’s comments were prepared under the aegis of the Institute’s Tax Reform Task Force and U.S. International Tax Committee. Benjamin Shreck, TEI Tax Counsel, coordinated the preparation of TEI’s submission.