Changes are coming to the international tax provisions of the TCJA, and this easy-to-read OnPoint presentation will highlight all you need to know about these tax proposals.
This vital resource summarizes the Senate Finance Committee’s draft legislation, including:
Changes to the GILTI regime:
- Eliminate DTIR and QBA from GILTI calculation
- Calculate on country-by-country basis
- Only tested income that is not high-tax test income would be subject to U.S. tax
Changes to the subpart F regime and foreign tax credit:
- Extend high-tax rules to foreign branch income
- Apply haircut for subpart F foreign tax credits
- Conform treatment of high-tax subpart F income
- Treat R&E expenses and stewardship expenses as 100% allocable to U.S.-source income
Changes to the §250 deduction and FDII:
- Reduce and equalize §250 deduction for FDII and net CFC tested income
- Eliminate DTIR and QBAI from FDII calculation
- Clarify that §78 gross-up amount is included for purposes of taxable income limitation
And BEAT and SHIELD.
Download this ready-to-share presentation today and help your clients prepare for these potential changes.