Page 154 - International Taxation IRS Training Guides

TCJA International Changes

 One-time transition tax on untaxed earnings of
certain

foreign corporations

foreign dividends, using 100% DRD, also
 Exemption of
the participation exemption
known as

F retained full and immediate taxation of
 Subpart

certain mobile controlled foreign corporation (CFC)

income; however,
new tax at reduced rate on other

known as Global Intangible Low-Taxed
CFC income,
Income or
GILTI

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