Here is the full legislative text of the Senate Tax Reform bill that just passed the Senate Finance Committee and which now will be likely modified and later voted on by the entire Senate.
It is entitled ‘‘Tax Cuts and Jobs Act’’ which is an amendment to the 1986 IRS code.
See also SECTION SUMMARIES in simpler language.
Anything in this latest version that helps or harms us?
“…Treatment of deferred foreign income upon transition to participation exemption system of taxation
Current Law: Generally, foreign income earned by a foreign subsidiary of a U.S. corporation is not subject to U.S. tax until it is distributed to the U.S. parent corporation as a dividend. Such dividends, minus credits for foreign taxes paid, are considered taxable income for the U.S. corporation.
In the Mark: For the last taxable year beginning before the dividend exemption takes effect, a U.S. corporation that is a 10-percent shareholder of a foreign corporation must include in income its pro rata share of the undistributed, non-previously-taxed post-1986 foreign earnings of the corporation. The subpart F inclusion is taxed at rates of 10 percent for earnings attributable to liquid assets and 5 percent for other earnings.”