Description

Cut through the static of the international provisions of the Tax Cuts and Jobs Act (TCJA) with a discussion on what we learned during the first tax filing season, including Global Intangible Low-Taxed Income (GILTI) and more. Guest Chris Clifton joins host Damien Martin to reflect on key takeaways and look to what’s ahead. Here’s what’s covered:

• The added complexity of the TCJA [01:25]
• The most surprising things about applying the international provisions [06:27]
  • Section 956 [07:03]
  • The new GILTI high-tax exception [09:26]
  • Overpayments with §965 [12:27]
  • Hybrid GILTI rule for partnerships and S corporations [14:34]
• Challenges with guidance on the 50 percent GILTI deduction with the §962 deduction [18:14]
• Areas where Chris is hoping to see more guidance [23:06]
• Approaching uncertainty after the TCJA [27:42]
• Discussing challenges and uncertainty with clients [29:36]
• Planning considerations for taxpayers after the TCJA [30:52]

BIO FOR GUEST

Chris Clifton is a managing director in BKD’s International Tax Services division. His focus is on international tax planning and compliance for domestic, foreign and multinational corporations in areas such as foreign tax credits, subpart F, withholding taxes and income tax treaties.

ADDITIONAL RESOURCES

Learn more from Chris about some of the complex provisions discussed in the podcast:

• "Simply Tax" Episode 10: The International Side of Tax Reform with Chris Clifton (January 25, 2018)
• International Tax & the TCJA presented by Chris Clifton (February 22, 2018)
• New GILTI Regulations Include High-Tax Exception Election, Change for Partnerships & S Corporations by Chris Clifton (June 21, 2019)

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A complete archive of our episodes is available on our website and YouTube playlist.

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