19 December 2025 When Profits Come Home: Repatriation and Taxation in the Post-OBBBA Era (CCH) In a recent article published in CCH's International Tax Journal, David M. Abrahams, a Managing Director with Ernst & Young LLP’s National Tax International Tax and Transaction Services (ITTS) practice, discusses recent developments under the "One Big Beautiful Bill Act" (OBBBA), focusing on the taxation of distributions by first-tier foreign subsidiaries directly to their U.S. corporate owners. The author's discussion begins with a review of the recent statutory (OBBBA) and regulatory changes relevant primarily to PTEP distributions from CFCs. Other OBBBA changes affecting the tax treatment of distributions from CFCs and non-controlled foreign subsidiaries are examined next. Finally, the article closes with an examination of the impact of recent guidance on the corporate alternative minimum tax (CAMT) treatment of PTEP and non-PTEP distributions. Document ID: 2025-2571 |
