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By Emilien LEBAS, Associate Partner, KPMG *
On 22 December 2017, President Trump signed into law the Tax Cuts and Jobs Act (TCJA). The US tax reform makes fundamental changes to the taxation of multinational groups of all sectors of the economy.
One of the objectives of the US tax reform was to discourage US taxpayers from ‘offshoring’ intangible assets and shifting related income outside the country. The TCJA attempts to address this objective through various provisions, including the foreign-derived intangible income (FDII) regime provisions of Sec. 250 of the Internal Revenue Code, the global intangible low-taxed income (GILTI) provisions of Sec. 951A, and the base-erosion and anti-abuse tax provisions (BEAT) of Sec. 59A...
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