Tax Cuts and Jobs Act & BEPS

In many respects, the TCJA changes are more significant than those enacted with the Tax Reform Act of 1986. Although the move to a participation exemption system may be the headline, the Section 951A GILTI provisions subject all foreign income and assets held by controlled foreign corporations (“CFCs”) to rigorous testing and reporting requirements. And, if the income is proven to be GILTI, it is immediately subject to U.S. taxation, effectively expanding the Subpart F anti-deferral regime.

Forte’s international tax expertise and proprietary software, VantagePoint, can assist in the transition under the new law.

Foreign Earnings & TCJA Transition Tax
Global Intangible Income: GILTI and FDII
BEPS/CbCR & the TCJA BEAT
Export Incentives: FDII and IC-DISCs