Page 156 - International Taxation IRS Training Guides
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Overview of Post-TCJA US Tax System
Payments from USP to 21% statutory rate (reduced
foreign related parties USP by FTCs) on USP income
subject to BEAT other than,
FDII, which is
taxed at
13.125%*
21% on subpart F income
(reduced by FTCs)
10.5%* on GILTI (partially 21% on branch income
FTCs, but new
reduced by (reduced by
FTCs, but
new basket) basket)
DRD for residual
100%
CFC FBR
* Effective tax rate resulting from deduction 11
