Talking Tax Reform: The Treatment of Foreign Profits in the Tax Cuts and Jobs Act


The Tax Cuts and Jobs Act (TCJA) significantly changed the way in which the tax code treats the foreign profits of U.S.-based multinational corporations.

The new tax law eliminated the additional domestic tax on foreign profits repatriated to the U.S. by enacting a “participation exemption,” the centerpiece of what is called a “territorial” corporate tax system.

At the same time, the TCJA enacted new anti-base erosion provisions aimed at income stripping and a minimum tax on certain foreign-source profits.

In this video, several of today’s leading international tax experts discuss the new international tax laws, including:

The new dividend exemption system

GILTI

FDII

BEAT

In addition to shedding light on these provisions and their workings, panelists discuss the real-world application of the U.S.’s new international tax system.

Panelists include:

Pat Brown, Vice President & Counsel, Tax, GE Power and Renewables

Dave Lewis, Former VP of Global Tax, Eli Lilly and Company

Kyle Pomerleau, Director of Federal Projects