On November 16, 2017, the House of Representatives passed a much anticipated tax reform bill, titled the Tax Cuts and Jobs Act (the House Plan), which was first introduced on November 2, 2017. The passage of the House Plan comes as the Senate is debating its own tax reform proposals. On November 21, 2017, the Senate Finance Committee released legislative text of the tax reform bill, titled the Tax Cuts and Jobs Act (the Senate Plan), which the Committee passed on November 16, 2017. The Senate Plan, like the parallel House Plan, would reduce the maximum corporate tax rate from 35% to 20% and move away from the current worldwide system of taxation to a territorial regime. However, both proposals also broaden the base of income subject to current US tax through the inclusion of a one-time tax on undistributed earnings of foreign subsidiaries of US corporations and the expansion of the existing subpart F rules by imposing a minimum tax on the earnings of foreign subsidiaries of US corporations. Additional limitations on the ability of US corporations that are members of multinational groups to deduct interest expense and certain payments to related foreign persons also mitigate the potential benefit from the proposed rate reduction and shift toward a territorial system.
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