Analysis

5 Thorny TCJA Issues Multinationals Need To Know About

Law360 (March 29, 2018, 7:58 PM EDT) -- The biggest tax code overhaul in more than 30 years radically revised the treatment of overseas income, making it a daunting task just to keep track of all the unexpected, unclear and sometimes unintended outcomes of the law's international provisions.

The Tax Cuts and Jobs Act, P.L. 115-97, moves the U.S. to a largely territorial tax system, exempting most of the worldwide profits of corporations. However, the new law also contains a slew of provisions to discourage U.S. companies from moving intangible assets offshore or stripping earnings out of American borders.

These sudden changes have left accountants and advisers scrambling to...

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