Key provisions of the new US tax code are:
• Reduction of the Corporate Income Tax rate from 35% to 21% (excl. state/federal taxes).
• 100% Dividend Participation Exemption.
• Limitations on Net Operating Loss.
• Mandatory One-Time Transition Tax.
• Various provisions to prevent avoidance and base erosion, including additional CFC rules, interest expense limitations, provisions that disallow a deduction in relation to related party payments and anti-hybrid rules.
Please see our blog for a more detailed overview of the key measures and attention points for multinational groups with a branch or company in the US.
