EDITOR’S NOTE -

Tax Reform (or whatever you want to call it) is in full swing as this edition of Tax Talk goes to press. The House has passed H.R. 1 and the Senate Finance Committee has approved its own version of the Tax Cuts and Jobs Act (the “TCJA”). A vote in the Senate is scheduled for the week after Thanksgiving, and, if we get that far, a House-Senate conference on the legislation will follow. Comparing the House and Senate bills, there are a number of areas of agreement, with some of the highlights being:

..Both bills include a participation exemption for dividends paid to a U.S. corporation from a 10% or more owned foreign corporation; ..Both bills include deemed repatriation provisions for offshore corporate earnings accumulated through the end of 2017...