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Tax Reform

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In news analysis, Mindy Herzfeld addresses technical problems introduced by the Tax Cuts and Jobs Act, focusing on the problems inherent in the interplay between the foreign tax credit regime and the new rules on global intangible low-taxed income.

Mindy Herzfeld reviews the international provisions of the Tax Cuts and Jobs Act, finding that the focus on large multinationals and individual owners of domestic businesses resulted in a patchwork of rules that apply unevenly to individual investors earning cross-border income, as well as to income earned from foreign businesses conducted in passthrough form.