Page 108 - International Taxation IRS Training Guides

Book & Tax Rules:

Foreign Earnings Post
TCJA

Book Tax

income does not
 Financial  USP’s
accounting rules
include all
generally require that necessarily
tax
income.
expense be calculated on foreign subsidiary
income (including
WW • Subpart F
at US
foreign subsidiaries) • GILTI
statutory
tax rate
regardless
of whether such
subject to tax for
income is
law purposes
tax

23