Tax Reform: Taxation of Income of Controlled Foreign Corporations

Lowell Yoder, David Noren and Elizabeth Chao wrote this bylined article on the significant expansion of Subpart F by the recently enacted tax bill. The authors wrote that while many longstanding planning issues remain under the new law, taxpayers must contend with significant complexity and uncertainty under the new global intangible low-taxed income (GILTI) and base erosion and anti-abuse tax (BEAT) provisions.