Repatriation: Deferral and Estate Implications

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.