Page 212 - International Taxation IRS Training Guides
P. 212
Review of Post-TCJA US Tax System
Payments from USP to 21% statutory rate (reduced
FTCs) on USP income
foreign related parties USP by
subject to BEAT other than,
taxed at
FDII, which is
13.125%*
CFC FBR
21% on subpart F income (reduced by 21% on branch income (reduced by
FTCs) FTCs, but new basket)
10.5%*
on GILTI (partially reduced by
FTCs, but new basket)
DRD for residual
100%
* Effective tax
rate resulting from deduction
67
