International Tax: Tax Reform Three Years Later

The Tax Cuts and Jobs Act brought many changes to U.S. taxpayers, including those who are shareholders in certain foreign corporations. One major change involves Global Intangible Low-Taxed Income (GILTI), which requires U.S. shareholders to include certain income of foreign corporations in U.S. taxable income, regardless of whether cash is distributed. As a result of the new law, U.S. compliance related to foreign corporations has become significantly more complex. Additionally, the GILTI regime creates planning opportunities for both corporations and individuals that can significantly lower U.S. tax liabilities.