As a part of the Tax Cuts and Jobs Act (TCJA), there are tax provisions that will affect U.S. shareholders of controlled foreign corporations (CFCs) for tax years beginning after December 31, 2017. The IRS recently issued guidance on these changes.
The TCJA shifts the U.S. corporate taxation of foreign earnings to a “quasi-territorial” system, which, for corporate shareholders of a foreign corporation, may result in no U.S. tax with respect to income of a CFC. However, ownership of a foreign corporation by a U.S. shareholder that is not a C corporation may produce less favorable […]
The Tax Cuts and Jobs Act is the biggest federal tax law change in over 30 years. Below are some significant changes affecting corporations. Note: Except where noted, the changes are effective for tax years 2018–2025.