Repatriation of CFC Earnings

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The TCJA supposedly enacted a territorial tax system providing a deduction or exclusion for distributions received by a domestic corporation from a CFC. However, there are a number of complex rules that apply when a domestic corporation repatriates earnings from a CFC, and income, gains or losses can result from a distribution.

Lowell D. Yoder provides an overview of the rules that must be considered when a CFC distributes previously taxed earnings and profits as well as when a CFC distributes earnings and profits that were not previously taxed.