Coming to terms with US tax reform in the shape of the Tax Cuts and Jobs Act, the most substantive change in US tax legislation since 1986. The broad intent was to reduce taxes for both individuals and corporations. The American abroad may not achieve this as amendments to the ownership attribution rules expands the definition of a US shareholder and circumstances where Controlled Foreign Corporation (CFC) rules apply the one time repatriation tax for 2017 and a global intangible low taxed income (GILTI) inclusion from 2018 onward. This tax reform will have a profound effect on the way foreign entities with a US footprint are structured which advisers need to come to terms with.
CPD: 1 Hour
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