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Advising International Business Ventures: Tax Reform and a Quasi-Territorial Tax System

In CFC, International Tax, Participation Exemption, Tax Reform by Jason B. FreemanLeave a Comment

The Tax Cuts and Jobs Act (“TCJA”) led a shift from a “worldwide” tax system towards a territorial tax system—more accurately, a “quasi”-territorial tax system.  The TCJA accomplished this through several major reforms.  First, it enacted a “toll charge,” or transition tax—a one-time tax on the deemed repatriation of earnings held offshore. In exchange, it implemented a “Participation Exemption System” that …