By Sidney Kess and Chaya Siegfried
CPA Journal
May 2018 Issue
Taxation of international activities has always been complex and rife with traps for the unwary. The Tax Cuts and Jobs Act of 2017 (TCJA) has completely changed the landscape of international taxation, but not, as one would hope, in the direction of simplification. Rather, it adds a layer of complexity to what was already an complicated system.
The most discussed provision in the TCJA is likely the “transition tax,” which results in a one-time deemed repatriation. The new Global Intangible Low Taxed Income (GILTI) provision may, however, have an even greater impact. In addition, there are several minor tweaks to the existing law that will, for the multinational corporations affected, have significant consequences.
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Published with permission from the CPA Journal.
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