4.6 International Tax Issues

1. The U.S. Taxation of Foreign Transactions

1) Worldwide tax system

2) Territorial tax system (after 2018)
Foreign-source portion of dividends received: 100% DRD (owns 10% or more)

3) Transition tax (one-time deemed repatriation tax)

2. Subpart F Income

Controlled foreign corporation (CFC)
Subpart F income: passive investment income or active income tied to are "related party".
(1) Foreign personal holding company (PHC) income
(2) Foreign base company sales income
(3) Foreign base company service income

3. Global Intangible Low-Taxed Income (GILTI) Tax

4. Foreign-Derived Intangible Income (FDII) Deduction

5. Base Erosion and Anti-abuse Tax (BEAT)