Page 95 - International Taxation IRS Training Guides
P. 95
Post-TCJA – IRA’s New Limited
Relevance
If no IRA, in addition to US federal tax liabilities on
taxable income such as subpart F and GILTI,
will need to currently account for the
companies
following:
liability for foreign withholding taxes on actual
• Deferred tax
of previously taxed foreign earnings.
repatriations
• Deferred tax
liability for foreign currency movements related to
that
withholding tax liability from year to year.
• Deferred tax
liability for state taxes.
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