While many of these international changes relate directly to U.S. corporations doing business outside the United States, they nevertheless will have a substantial impact on U.S. individuals with the same overseas activities or assets.
One notable change under the new law was the reduction of the maximum U.S. corporate income tax rate from 35% to 21%. Not surprisingly, this change will have a corresponding impact on the ability of U.S. shareholders (both corporations and individuals) of controlled foreign corporations (“CFCs”) to qualify for the Section 954(b)(4) “high-tax exception” from Subpart F income. This is because the effective foreign tax rate imposed on a CFC that is needed to qualify for this purpose must be greater than 90% of the U.S. corporate tax rate. Therefore, this exception now will be available when the effective rate of foreign tax is greater than 18.9% (as opposed to 31.5% under prior law).
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Jeffrey L. Rubinger and Summer Ayers LePree provide a comprehensive overview of the impactful changes brought about by the Tax Cuts and Jobs Act (TCJA), particularly in international tax provisions. The reduction of the maximum U.S. corporate income tax rate from 35% to 21% stands out as a significant modification. This change not only affects U.S. corporations but also has implications for individuals with overseas activities or assets. The adjustment in the high-tax exception criteria under Section 954(b)(4) highlights the intricate adjustments necessitated by this reform.
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