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The 2017 tax reform reconciliation act (the Act) is having a substantial impact on US taxpayers. Among the most significant areas of impact are the international tax reform provisions and their interactions with each other.

These provisions include Section 965 (the ‘toll charge’ on the deemed repatriation of foreign earnings); the Section 951A provisions on global intangible low-taxed income, or GILTI; the Section 250 provisions on foreign deemed intangible income, or FDII; the new Section 163(j) interest deduction limitations; and the Section 59A base erosion and anti-abuse tax, or BEAT.  Foreign tax laws and pending changes thereto, including changes to treaties, also are important variables to consider, as is the possible impact of certain tax attributes of US shareholders, such as an overall domestic loss (ODL).

PwC on May 2 hosted a webcast featuring PwC specialists who discussed some of the key interactions among these provisions. This Insight highlights some of those discussions. Watch the webcast replay and register for future webcasts in PwC’s Tax Reform Readiness series, which addresses other areas of interest affected by tax reform. The next webcast — Tax reform readiness: Impact on deals and JV alliances — will take place on May 9, from 2:00 PM - 3:00 PM (EDT).

Read more in the attached PwC Tax Insights newsalert.

For further details, please contact one of our US tax specialists in London - Tom PattenJoe Superty, or your usual PwC contact.