The Tax Cuts and Jobs Act: Insights and Planning Tips From International Portions of New Tax Law

The bill ("the Bill") sent to the President on December 20, 2017, reflects a sea change in Congress's philosophy about taxing domestic corporate income from overseas. As you review the new law, don't be discouraged if you have trouble understanding it. Because it was drawn in such haste, some of its provisions are, at best, awkwardly phrased and others are borderline indecipherable.
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The bill ("the Bill") sent to the President on December 20, 2017, reflects a sea change in Congress's philosophy about taxing domestic corporate income from overseas. As you review the new law, don't be discouraged if you have trouble understanding it. Because it was drawn in such haste, some of its provisions are, at best, awkwardly phrased and others are borderline indecipherable.

Rufus v. Rhoades is the co-author of Rhoades & Langer, U.S. International Taxation and Tax Treaties, a six-volume treatise published by LexisNexis Matthew Bender. In addition to writing, Mr. Rhoades practices law with a concentration on International Tax matters and in all facets of federal and state income tax matters, including work with the Internal Revenue Service (IRS) and the California Franchise Tax Board on a number of controversial issues. Mr. Rhoades has received the Dana Latham Memorial Award for Lifetime Achievement in Taxation, which was presented by the Los Angeles County Bar Association Section on Taxation, and the Joanne Garvey Award presented by the California State Bar Section on Taxation for substantial lifetime contributions to the field of tax law.

Cynthia D. Brittain is Northern Trust Company's Trust Advisor Team Lead for the Santa Barbara Region. Prior to joining Northern Trust, Ms. Brittain served as Counsel at McKenna, Long & Aldridge, LLP in Los Angeles, CA, where she focused her practice on domestic and international estate and tax planning. Ms. Brittain received her LL.M in Taxation from The University of San Diego, and her Juris Doctor from California Western School of Law where she served on Law Review/International Law Journal.

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