As many readers are aware, the Tax Cuts and Jobs Act of 2017 (TCJA) dramatically changed the rules governing controlled foreign corporations (CFCs), including the introduction of a one-time transition tax on deferred foreign income, a new tax on global intangible low taxed income (GILTI) and other changes that expanded the scope of the CFC regime. However, one provision many advisors are still grappling with is the repeal of the limitation on downward attribution in former Internal Revenue
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