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January 31, 2018

New Law Includes Loophole That Lets Taxpayers Reduce Tax on Repatriated Income

A loophole in the Tax Cuts and Jobs Act (TCJA) could allow multinational corporations like Apple to avoid paying billions of dollars in taxes on profits stashed overseas.

The TCJA imposes a transition tax on untaxed foreign earnings of foreign subsidiaries of U.S. companies by deeming those earnings to be repatriated. But the law contains a loophole that allows taxpayers to convert income that would otherwise be taxed at 15.5% (cash holdings) into income that is taxed at 8% (more illiquid investments).

And multinationals could have leeway to shift foreign earnings into the 8% tax bracket. (more…)

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Categories: International Business Issues
Tags: international tax, multinational corporations, Tax Cuts and Jobs Act, TCJA,

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