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Repatriation: Deferral and Estate Implications

Dealing with the transition tax imposed by the Tax Cuts and Jobs Act.

While the Tax Cuts and Jobs Act (TJCA) produced many complicated changes that practitioners are still studying and debating, there’s been scant mention of a change that focused on international tax from a U.S. perspective, which can acutely impact a domestic estate. That issue is the transition tax for certain specified foreign corporations (SFCs). This tax may generate a cash liquidity crunch and warrants consideration of some potential planning concepts.


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