International Taxation and Foreign Tax Credits

Assume that you are a CPA employed as an international tax consultant hired to provide advice to a U.S.-
based client expanding operations into foreign markets. To complete this assignment please select a U.S.-
based corporation that has expanded into foreign markets within the last seven years.
Using the Internet, conduct research on the tax impacts for U.S. companies expanding into foreign markets.
Write a four to six (4-6) page paper in which you:
1. Based on your research, analyze the major impact of the Tax Cuts and Jobs Act on the use of controlled
foreign corporations to expand abroad. Examine two (2) methods you would recommend to the client to
circumvent the provisions of the Tax Cuts and Jobs Act on subpart F to reduce the client’s tax liability.
Provide at least two (2) examples to support your recommendations.
2. Based on your research, create a plan for the client to lower taxes by reinvesting profits and thereby lower
the company’s tax liability. Provide at least one example to support your plan.
3. Develop a strategy for the client to neutralize the impact of the Tax Cuts and Jobs Act on the immediate
U.S. taxation of deferred income from foreign subsidiaries’ earnings and profits (E&P) over an eight-year
period. Provide examples to support your plan.
4. Analyze the foreign tax credits available to your client. Propose at least three (3) tax credits the client
could use and the impact of the credits on other foreign loss income. Provide examples to support your
recommendations.