- Tax Consequences of Foreign Investments in US Real Estate
- The American Families Plan Affect on Section 1031 Exchanges
- State And Local Tax (SALT) Workaround is coming to California
- The American Families Plan Potential Impact on Real Estate
- Tax Season is Over. Now What?
- Proposed Initiatives Obtain Funding from Selective Tax Increases
The New Tax Law H.R. 1, which is generally effective for years starting in 2018, includes a provision that will impact U.S. people owning controlled foreign corporations for the 2017 tax year. Generally, H.R. 1 requires U.S. taxpayers owning controlled foreign corporations (CFC) to include their portion of the corporation’s accumulated earnings & profits in income as a mandatory repatriation income inclusion on the 2017 income tax returns. The mandatory repatriation income inclusion will be taxed at a rate of either 15.5% or 8% depending on foreign company’s cash position on the testing dates. Further, going forward, owners of controlled foreign corporations will have limited ability to defer the income in the foreign corporations. If you or your company owns a foreign corporation, you should contact your tax advisor as soon as possible to discuss the tax implications.