ECOVIS Global published an article by International Tax Partner Andre Benayoun, about possible complications from a lower corporate tax in the United States.
ECOVIS Global
By Andre Benayoun, Partner, International Tax
Excerpt:
Under the US Controlled Foreign Income (CFC) regime, non-U.S. entities controlled by U.S. taxpayers may have their income picked up on a current basis in the U.S. without allowing for the customary deferral that would come from operating in subsidiary form… The new federal income tax rates discussed above may cause some U.S. corporations to be treated as “low-taxed” for purposes of a parent country’s CFC regime.