Page 31 - International Taxation IRS Training Guides

Outbound - Repatriation

 Once a U.S. MNE
has lowered its ETR by shifting

CFCs, the taxpayer may want
income to a lower-tax
to the U.S.
to repatriate the cash accumulated back

without
incurring a residual U.S. tax (35% less
on the repatriated earnings.
available credits)

 Repatriation

distributions – cash may be subject to current U.S. tax
• Actual
in U.S. property” such as CFC loans to U.S.
• “Investment
affiliates,
CFC purchases of tangible property located in the
stock issued by a related domestic corporation are
U.S. or
subject
to current U.S. tax like taxable distributions.

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