By David Dreier and Grayson Weeks (March 20, 2018, 6:58 PM EDT) -- The new federal tax rules, informally known as the Tax Cuts and Jobs Act, signed into law on Dec. 22, 2017, significantly expand the situations in which a foreign corporation will be treated as a controlled foreign corporation, or CFC, and expand the types of income of the CFC that certain U.S. shareholders must include annually on their tax returns. In particular, foreign corporations that are owned by a foreign parent might now be CFCs if the foreign parent also directly or indirectly owns at least one U.S. corporation or if the foreign parent has an owner that also directly or indirectly owns a U.S. corporation. As a result of this expansion, many U.S. shareholders who were not previously affected by the CFC rules are now subject to annual income inclusions. In addition, there is now a new tax — the GILTI tax — imposed on U.S. shareholders who hold an interest in a CFC. Thus, many U.S. shareholders who were previously subject to the CFC rules are now subject to additional annual income inclusions. Some of these changes are effective for the 2017 tax year....