Maximize the utilization of FTC and DPAD and more amidst the TCJA transition tax on foreign deferred income for 2017.

All CFCs' income and assets must be tested for GILTI/Subpart F inclusions, while FDII provides a valuable U.S. export incentive.

Following G20/OECD BEPS, governments continue to focus on transfer pricing and the TCJA imposes the BEAT.

The FDII deduction effectively reduces corporate tax to 13.125%, while the IC-DISC continues to help U.S. exports of all sizes.