Page 169 - International Taxation IRS Training Guides

Transition Tax (Cont’d)

 This transition tax is effectuated by increasing the

subpart F income of a specified foreign corporation

(SFC) for its last tax year beginning before Jan. 1,

2018 by the greater of certain of its post-1986

earnings and profits (E&P) as of:

2, 2017 (which is the date that TCJA was introduced in
• November

the House), or
31, 2017
• December

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