COORDINATION OF DISTRIBUTIONS AND MANDATORY REPATRIATION

The House Ways & Means Committee staff appears to be leveraging the mandatory repatriation proposal included in the draft legislation (the "Tax Reform Act of 2014") released for public comment in December 2014 (the "2014 Camp Proposal"). The 2014 Camp Proposal would require a...

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Bibliographic Details
Published in:Practical Tax Strategies 2017-07, Vol.99 (1), p.34
Main Authors: Vyas, Rahul, Stenger, Allen, Murillo, Jose
Format: Article
Language:English
Subjects:
Bills
Controlled foreign corporations
Dividend distributions
Dividends
Foreign source income
Foreign subsidiaries
Internal Revenue Code
Repatriation
Stockholders
Tax reform
Taxable income
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Summary:The House Ways & Means Committee staff appears to be leveraging the mandatory repatriation proposal included in the draft legislation (the "Tax Reform Act of 2014") released for public comment in December 2014 (the "2014 Camp Proposal"). The 2014 Camp Proposal would require a U.S. shareholder to include, in its gross income, its "pro rata share" of the aggregate net positive deferred foreign earnings ("deferred foreign earnings") of each of its foreign subsidiaries that qualifies as a "specified foreign corporation": a controlled foreign corporation (CFC) or a foreign corporation with respect to which at least one U.S. corporation owns at least a 10% voting interest, directly or indirectly (referred to generally as "Section 902 corporation").
ISSN:1523-6250