If you are a U.S. person* who owns stock of a foreign corporation, we encourage you to continue reading this alert. Here we explain how your income tax liability for 2017 may be severely affected by a new provision introduced by the Tax Cuts and Jobs Act (the “TCJA”).**
On December 22, 2017, President Trump signed the TCJA into law, which represents the most significant tax reform since 1986. Of particular significance are the changes related to the enactment of a new participation exemption regime that effectively exempts from U.S. taxation dividends paid by foreign corporations to their U.S. corporate shareholders.
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