Page 12 - Tax Reforms - Businesses

Participation Exemption System (4/9)

Participation Exemption
System for Taxation of
foreign income

The new law enacts a participation
exemption system for the taxation
of certain foreign income. New

proposed regulations are intended
to ensure the application of section

956 is consistent with this new
system and reduce the amount
determined under section 956 with

respect to certain domestic
corporations and stock they own

(or are treated as owning) in
controlled foreign corporations
(CFCs).

https://lentcpa.com