Episode 10 – The International Side of Tax Reform

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Part of the TCJA Series

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We’re back to help you cut through the static of the Tax Cuts and Jobs Act with the second in a series of episodes that breaks down what the new tax law means for you and your business. BKD’s Chris Clifton covers the international provisions of the new tax law and explains how they fit into the larger world of international taxation.

Some of the important areas covered in this episode include:

  • Shift to a territorial system @ 2:28
  • Deemed repatriation @ 4:17
  • Global intangible low-taxed income (GILTI) @ 10:27
  • Base erosion anti-abuse tax (BEAT) @ 14:08
  • Limitation on deduction for interest expense @ 18:50
  • Areas where additional guidance is needed @ 22:25
  • Foreign derived intangible income (FDII) @ 29:27
  • International considerations for converting an S corp to a C corp @ 36:42
  • Key takeaways @ 40:25

GUEST BIO: Chris Clifton is a managing director in BKD’s International Tax Services division. His focus is on international tax planning and compliance for domestic, foreign and multinational corporations in areas such as foreign tax credits, subpart F, withholding taxes and income tax treaties.


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