McDermott Will & Schulte, a global law firm

Stephen Kranz, Diann Smith, and Mark Nebergall wrote in a blog post cited here that the new tax bills would treat foreign earnings and profits of some U.S.-owned businesses as subpart F income, allowing a deduction for a percentage of the deemed repatriation. If approved, the authors wrote, the “deductions will also flow through to the states taxing such income, providing a reduced tax rate at the state level as well.”