Navigating US Tax Reform: International Implications

HR 1, formerly known as the Tax Cuts and Jobs Act, profoundly changes the US tax treatment of the international operations of US businesses and has significant implications on the US operations of foreign businesses. Join Morgan Lewis for a 90-minute tour of the issues that most affect international businesses.

TOPICS WILL INCLUDE:

• Change from indirect foreign tax credits to a participation exemption system
• Transition tax and Notice 2018-07
• Taxation of foreign intangible income (GILTI and FDII)
• Taxation of outbound transfers
• Base erosion and anti-abuse tax
• Other changes affecting US operations of foreign businesses