March 2018 JD Supra

The Tax Cuts and Jobs Act (TCJA) includes a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax” regardless of whether earnings have actually been repatriated.

According to the TCJA:  https://www.jdsupra.com/legalnews/shareholders-of-s-corps-can-defer-19027/