“[The tax plan] will provide a deemed repatriation of corporate profits held offshore at a one-time tax rate of 10 percent.”
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The Tax Cuts and Jobs Act, signed December 22, 2017, enacted the promised mechanism: section 965 imposes a one-time deemed-repatriation transition tax on the accumulated untaxed foreign earnings of specified foreign corporations. However, the effective rates were set at 15.5 percent on cash and cash equivalents and 8 percent on other assets — generally between 8 and 15.5 percent — rather than the flat 10 percent rate promised in September 2015.
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