TCJA Limits Means For Inversions, But Incentives Remain

Law360 (April 16, 2018, 5:03 PM EDT) -- Despite the business-friendly tone of the U.S. tax overhaul, specialists say the new law’s treatment of offshore earnings could still push some companies to move their headquarters overseas if they can make it over the rising hurdles against inversions.

The Tax Cuts and Jobs Act, P.L. 115-97, slashed the top corporate income tax rate from 35 percent to 21 percent and exempted from taxation most of the income earned outside American borders. However, the legislative overhaul stopped short of moving the U.S. to a pure territorial system, in part by creating a new category of taxable offshore earnings.

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