Page 125 - International Taxation IRS Training Guides

Example C-7.1:

Income Tax Footnotes

TCJA Examples:

 On December 22, 2017, the TCJA was enacted into law, which

significantly changes existing US tax law. The TCJA reduced the US
federal statutory tax rate from 35% to 21% effective January 1, 2018. For

fiscal year 2018 entities, the US federal statutory tax rate would be

equal to a blending of the pre-TCJA tax rate of 35% and a post-
TCJA tax rate of 21%. (This footnote would likely also include the entity-

specific narrative explaining exactly how the TCJA affected the entity’s

financial statements.)

 The TCJA includes a provision to tax global intangible low-taxed
income (“GILTI”) of foreign subsidiaries and a base erosion anti-

abuse tax (“BEAT”) measure that taxes certain payments between a

US corporation and its foreign subsidiaries. (This footnote would likely
also include the entity-specific narrative explaining exactly how the GILTI

and BEAT affected the entity’s financial statements.)

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