It is Six of One, Half a Dozen of the Other – Changes to U.S. Shareholders and Downward Attribution
The Tax Cuts and Jobs Act of 2017 ushered in a host of tax provisions you may have heard of, including the Repatriation Tax,[1] GILTI,[2] and Base Erosion[3] taxes. But, there are some little-known changes that may make a big difference on the 2017 [...]