The rules are complex. US individuals and businesses were subject to the tax if their ownership percentage in a foreign corporation exceeded certain thresholds in late 2017. For example, the tax often applied to:

  • Individuals who, together with family members, owned or controlled a foreign corporation (generally, had more than 50% ownership)
  • Individuals who had at least a 10% voting interest in a foreign corporation, if at least one of the other 10% shareholders was a US domestic corporation
  • Businesses with certain levels of control or ownership in foreign corporations.

Learn more about the Repatriation Tax.