Complete Analysis of the Tax Cuts and Jobs Act
Thomson Reuters Checkpoint
Douglas S. Stransky contributed to the Complete Analysis of the Tax Cuts and Jobs Act, published by Thomson Reuters Checkpoint (2018). In his contribution, Mr. Stransky presents his viewpoint regarding amended Internal Revenue Code section 965. This "deemed repatriation" provision requires U.S. Shareholders to include the earnings and profits of a greater than 10% controlled foreign subsidiary into income as of November 2, 2017 or December 31, 2017, depending on which of the two dates results in the higher income inclusion.