Skip navigation

U.S. Owners of Foreign Corporations Face New Hurdles

The innocent found GILTI.

The Tax Cuts and Jobs Act of 2017 (TCJA) had a dramatic impact on U.S. owners of closely held foreign corporations. TCJA overhauled many international provisions of the Internal Revenue Code, but few areas saw as many changes as the controlled foreign corporation (CFC) rules. These changes were part of a broader constellation of provisions targeted at U.S. multinational corporations that were intended to reduce incentives for U.S. companies to shift earnings overseas without putting U.S.

All access premium subscription

Your subscription will include 12 months of Trusts & Estates magazine and access to premium content on

Hide comments


  • Allowed HTML tags: <em> <strong> <blockquote> <br> <p>

Plain text

  • No HTML tags allowed.
  • Web page addresses and e-mail addresses turn into links automatically.
  • Lines and paragraphs break automatically.