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Expert Analysis

An Important International Provision In The Tax Act

By Charles Purcell, Adam Tejeda, Won-Han Cheng and Elizabeth Crouse (January 16, 2018, 12:24 PM EST) -- In addition to the very significant changes to the domestic provisions of the Internal Revenue Code, the Tax Cut and Jobs Act made very significant changes to the taxation of foreign income of U.S. persons. This article will discuss one of the more important foreign provisions that apply to investment funds. These changes appear to eliminate the benefit of deferral for income earned though controlled foreign corporations (CFCs) above a permitted rate of return on capital invested in tangible property outside the United States by CFCs....

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