The U.S. has shifted from a largely worldwide tax system to a mostly territorial system. How does that affect your clients and international taxes?
One of the goals of tax reform was to lower the tax rate and to simplify, and make territorial, the international tax regime. The Tax Cuts and Jobs Act (TCJA) almost did that … but not quite. The keystone is the participation exemption which is the deduction of 100% of foreign source portion of dividends from certain foreign corporations. This video reviews the participation exemption, transition tax, GILTI, and FDII; as well as discusses dispositions of partnership interest
McDermott Will & Emery
- Partner in the Washington, D.C. office of McDermott Will & Emery LLP
- Practice emphasizes all aspects of U.S. and international tax, and tax controversy
- Experienced with U.S. and international tax issues relating to multi-international corporations
- Represented taxpayers before the U.S. Tax Court, Court of Federal Claims, and the U.S. Senate
- Admitted to the District of Columbia Bar
- J.D. degree, Duke University School of Law; B.A. degree, Brigham Young University
- Can be contacted at 202-756-8777 or [email protected]
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