February 2018 JD Supra

The “Tax Cuts and Jobs Act” (the “Act”) has 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”.  This mandatory “transition tax” or “repatriating charge” is due by U.S. Shareholder Taxpayers regardless

https://www.jdsupra.com/legalnews/u-s-10-shareholder-taxpayers-have-a-new-87839/