Page 382 - Large Business IRS Training Guides

Tax

Reform 1

• The Tax
Cuts & Jobs Act (TCJA)…

• Significantly
modified the U.S. system of international
U.S. corporations
taxation for

• This included substantial changes to international deferral

(some of what might have been considered timing

previously, is now more urgent  now or never)

• “Partial territoriality” going forward  0% partly

• Corporate domestic income rate change 35%  21%

• 13.125%
effective rate on Foreign-Derived Intangible Income (FDII)
• 10.5%
effective rate on Global Intangible Low-Taxed Income (GILTI)
• Lower
effective rates for FDII & GILTI achieved through special
deduction (IRC 250)

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