Controlled Foreign Corp. Restructuring For US Taxpayers

By Carl Merino and Dina Kapur Sanna (August 13, 2018, 12:48 PM EDT) -- Few areas of the tax law were as heavily impacted by the Tax Cuts and Jobs Act as the rules governing the taxation of foreign income. TCJA introduced a number of changes targeting U.S. multinationals doing business abroad, including, among other things, a 100 percent deduction for qualifying foreign source dividends from foreign subsidiaries, a transition tax on deferred foreign income of specified foreign corporations, the new global intangible low taxed income, or GILTI, tax regime and other provisions impacting U.S. owners of closely held foreign companies....

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