Our TCJA Implementation Services focus on three interrelated objectives:
- Section 965(a) Transition Tax – Calculating deferred foreign income for each specified foreign corporation, their related inclusion amount and optimizing the impact of the inclusions on the U.S. shareholders’ overall tax position, including DPAD, FTC and other valuable tax attributes.
- Global Intangible Income – The GILTI provisions dramatically expand Subpart F, creating an unprecedented level of integration between CFCs and their U.S. shareholders. We help clients analyze and implement appropriate allocation and apportionment methodologies to optimize the overall GILTI/FDII deduction.
- Base Erosion – VantagePoint is the ideal tool for analyzing supply-chain and transfer pricing decisions and provides the information necessary to comply with the new Base Erosion Anti-Avoidance Tax and the BEPS CbCR requirements.