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US tax reform: outbound investment

Speed read
Since September 2018, the US Treasury and IRS have issued four sets of proposed regulations, which, if adopted, will implement the most significant international changes made by the 2017 tax reforms. The two sets of proposed regulations discussed in this article concern US multinationals that operate outside of the US. The proposed regulations concern the current taxation of US shareholders on their share of global intangible low-taxed income (GILTI) of the controlled foreign corporations (CFCs) of which they are shareholder (whether or not that income is distributed to the shareholder) and the provisions implementing a fundamental change in the availability of indirect or ‘deemed paid’ foreign tax credits for US corporations holding shares in CFCs.

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