Insights

U.S. Switches to Territorial Tax System

Article Excerpt:

Unless you have been under a rock or in a long hibernation, you are aware that significant tax reform [Tax Cuts and Jobs Act (H.R.1)] has passed. The last such reform dates back to the Reagan years in the mid-1980s. It may surprise you, but no area within the Act was more affected than the taxation of income earned outside the U.S. As a result of the new law, the U.S. international tax system has completely shifted course from taxing worldwide active business income to a territorial system whereby foreign-source income gets, in many cases, a free pass.