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Across the pond
KEY POINTS
- Before the reforms the US had one of the highest headline rates of corporate tax in the world.
- Mandatory one-off transition tax has been introduced for undistributed earnings and profits of some controlled foreign corporations.
- New taxes ensure income is subject to the same rate US tax whether it is earned inside or outside the country.
- The base erosion anti-abuse tax is to discourage US companies using foreign affiliates.
The US federal tax system is undergoing the largest and most significant reform in more than 30 years. The Tax Cuts and Jobs Act (TCJA) which was signed into law on 22 December 2017 introduced sweeping and fundamental changes. The details and application of these are still being developed through a stream of lengthy regulations and guidance flowing from the US tax authorities...
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