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http://citizenshipsolutions.ca/2019/03/12/us-treasury-interprets-section-962-election-to-mean-that-individual-shareholders-are-entitled-to-50-exclusion-of-gilti-income-when-calculating-income-attributed/
US Treasury interprets Section 962 Election to mean that individual shareholders are entitled to 50% exclusion of #GILTI income when calculating income attributed