International Provisions in U.S. Tax Reform - A Closer Look

Tax Law Update | December.22.2017

Tax Reform has been approved by Congress and was signed into law by President Trump. In the international sphere, the changes will be monumental, and include the following:

  • New Participation Exemption Regime
  • Deemed Repatriation Tax
  • New Constructive Ownership Rules
  • New Anti-Deferral Rules Designed to Tax Income from Intangibles
  • Repeal of Indirect Foreign Tax Credit
  • New Base Erosion Minimum Tax
  • New Anti-Hybrid Provisions
  • New Limits on Business Interest Deductions
  • Look-Through Treatment on Sales of Interests in Partnerships Engaged in a U.S. Business
Orrick's international tax team goes into a deeper dive with respect to the above in order to help outline what is about to change and what the major impacts are likely to be. Read the complete text here.