This provision allows US companies easier access to pools of offshore cash through payment of a one-time tax on profits held overseas, payable over eight years. With an estimated $2.6 trillion stockpiled offshore, the rule change is triggering an influx of new liquidity. Moreover, new foreign earnings are free of US tax. The US has moved to “Territorial” vs “Global” tax system.

We're tracking: - Strategies to redeploy the cash - Reporting implications - IRS clarifications