TRUMP TAX REFORM: ONE SENTENCE THAT SCREWS FOREIGN COMPANIES (Part II)

Let’s talk a little more about one of the consequences of Trump Tax Reform that I mentioned in the first part of this series, to wit—a mandatory repatriation tax that is now included in the new Tax Cuts and Jobs Act. Remember, one little change in the new Act—“Section 958(b) is amended by striking paragraph (4)”—causes a bunch of foreign …

TRUMP TAX REFORM: ONE SENTENCE THAT SCREWS FOREIGN COMPANIES

It snuck up on us like a fire ant in your underwear. A little-known, little-followed, late added provision of the new U.S. Tax Cuts and Jobs Act that has the unintended consequence of forcing a foreign company to file detailed information with the IRS about all its non-US subsidiaries. The offending provision states simply: “Section 958(b) is amended—by striking paragraph …