Special Edition | US tax reform: A sea change for international taxation

Host: Rochelle Kleczynski, partner, Deloitte Tax LLP
1 Overview CPE credit | Taxes

The Tax Cuts and Jobs Act includes significant modifications to international provisions of the US Tax Code. What should US companies know? We'll discuss:

• Section 965 rules addressing the immediate taxation of deferred earnings and the participation exemption enacted under section 245A.
• Provisions applicable to controlled foreign corporations, including global intangible low taxed income. 
• Foreign-derived intangible income and other rules applicable to the taxation of intangible property. 
• Significant and broadly applicable base erosion measures such as the base erosion anti-abuse tax interest limitations under section 163 and hybrid payment rules.
• Modifications to existing law relevant to the application of the new provisions.

Participants will learn about how these provisions might impact their business and resulting tax planning considerations.