Objective
- Help advise clients with investments in foreign countries regarding the new tax rules that result from the Tax Cuts and Jobs Act of 2017
Highlights
- Provision allowing a U.S. corporate shareholder to receive a 100% dividend received deduction for dividends received from a foreign corporation
- Requirement that taxpayers recognize as subpart F income all undistributed earnings of a foreign corporation
- Requirement that a U.S. shareholder of any CFC include Global Intangible Low-Taxed Income (GILTI) in the shareholder’s gross income during the current year
- Repeal of Section 958(b)(4) resulting in the attribution of a foreign corporation’s ownership in an affiliated foreign corporation to a U.S. shareholder
Designed For
Tax practitioners who anticipate advising clients with investments in or doing business in foreign countries or who have investments in businesses that doPrerequisite
A basic understanding of the tax rules relating to individual income taxAdvanced Preparation
None