The Importance of Controlled Foreign Corporations

Question Description

According to the course text, the United States has employed a worldwide system of taxation for the past 100 years. The Tax Cuts and Jobs Act (TCJA) upended this system. Imagine you are an international tax consultant advising a client on the impact of P.L. 115-97, the law known as the Tax Cuts and Jobs Act, on the taxation of a controlled foreign corporation (CFC).

Analyze two changes to CFCs and advise your client on the actions necessary to reduce current and future tax liability as a result of these charges.
Create a scenario reflecting the taxation under the prior tax and current law to support your recommendations.
Read the article “IRS Issues Proposed Regs. for GILTI Inclusions.” This article discusses proposed new rules under the global intangible low-taxed income (GILTI) provision, created by the Tax Cuts and Jobs Act.

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