Today the IRS published the proposed GILTI regulations. The preamble to the regulations includes the following sentence:
In addition, a requirement that a partnership’s basis in specified tangible property be measured on the last day of a CFC partner’s taxable year could be burdensome for partnerships that have one or more CFC partners with taxable years that do not coincide with the partnership’s taxable year and, in those cases, would have the effect of decoupling the CFC partner’s share of the basis of partnership property used to compute the CFC partner’s QBAI from the CFC partner’s distributive share of the partnership’s income from the property that is taken into account in computing the CFC partner’s tested income.
By my count, this sentence has 100 words. Perhaps a bit long for a single sentence. As my wife commented: How is someone supposed to comprehend such a long sentence?