TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Tuesday, November 27, 2018

Anomalies In The Transition To Territoriality Under The TCJA

Libin Zhang (Roberts & Holland, New York) & Joshua Rabinovits (Roberts & Holland, New York), The End of Eternity: Anomalies in Transition to Territoriality, 159 Tax Notes 621 (2018):

The law formerly known as the Tax Cuts and Jobs Act of 2017 imposed a U.S. tax on the undistributed foreign earnings of certain foreign corporations. This tax on deemed repatriation income, under new section 965 of the Code, has some broad and surprising effects, particularly for individual shareholders of foreign corporations.

This Special Report in Tax Notes discusses some issues under section 965, such as the shareholders and corporations affected by the tax, the amount of the section 965(c) deduction in 2017 and 2018, and the various elections to defer the tax.

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