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Owning Controlled Foreign Companies

The New Tax Law H.R. 1, which is generally effective for years starting in 2018, includes a provision that will impact U.S. people owning controlled foreign corporations for the 2017 tax year. Generally, H.R. 1 requires U.S. taxpayers owning controlled foreign corporations (CFC) to include their portion of the corporation’s accumulated earnings & profits in income as a mandatory repatriation income inclusion on the 2017 income tax returns. The mandatory repatriation income inclusion will be taxed at a rate of either 15.5% or 8% depending on foreign company’s cash position on the testing dates. Further, going forward, owners of controlled foreign corporations will have limited ability to defer the income in the foreign corporations. If you or your company owns a foreign corporation, you should contact your tax advisor as soon as possible to discuss the tax implications.