Abstract
This paper is prepared to take a look at a unique tax
provision in the United States 2017 Tax Act (Tax Cuts and Jobs Act of 2017)
dealing with foreign earnings of United States multinational firms that are
engaged in business activities in many countries throughout the world. This act dramatically changed the tax status
of typical foreign earnings of United States multinational corporations as far
as United States taxation is concerned.
However, in light of this dramatic change, the unique tax provision that
was also added in the United States tax law in the 2017 Tax Act that this
article addresses tries to ensure that that dramatic change in the tax status
of typical foreign earnings of United States multinational corporations did not
go too far. This paper looks at this
unique tax provision in terms of its purpose, application and, as much as
possible, its future in United States tax laws.
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