Tax Law Changes

Make It Stand Out.

By now, I am sure you have read the tax law changes as they are applicable to individuals, pass-through businesses, and corporations. In this email, I want to focus on the international tax law changes. Specifically, how the changes in these provisions affect your small to middle market multinational clients. I will highlight four provisions which I think will have the most impact and will provide a bullet point summary of the remaining changes. Please reach out to me any time you want to have a discussion on these new laws and how they will impact your multinational clients.

In general, Section 245A allows a US corporate shareholders to receive a 100% dividend received dividend for dividends received from a foreign corporation.

At a very high level, the amount of the transition tax is calculated by taking the greater of E&P amounts on 11/2/2017 and 12/31/2017. The amount of the E&P that is related to cash positions and liquid assets is taxed at 15.5% and the remaining is taxed at 8%.