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The Treatment of Foreign Profits in the Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act (TCJA) significantly changed the way in which the tax code treats the foreign profits of U.S.-based multinational corporations.

The new tax law eliminated the additional domestic tax on foreign profits repatriated to the U.S. by enacting a “participation exemption,” the centerpiece of what is called a “territorial” corporate tax system.

At the same time, the TCJA enacted new anti-base erosion provisions aimed at income stripping and a minimum tax on certain foreign-source profits.

On Friday, May 4th at 12 noon, we will bring together several of today’s leading international tax experts for a detailed discussion of the new international tax laws, including but not limited to:

  • The new dividend exemption system
  • FDII
  • BEAT

In addition to shedding light on these provisions and their workings, panelists will discuss the real-world application of the U.S.’s new international tax system.

Panelists will include: 

  • Pat Brown, Vice President & Counsel, Tax, GE Power and Renewables
  • Dave Lewis, Former VP of Global Tax, Eli Lilly and Company
  • Kyle Pomerleau, Director of Federal Projects

Tax Foundation President Scott Hodge will moderate. Food will be served.