Repatriating income to the U.S. has benefits.

The Tax Cuts and Jobs Act (TCJA) imposes a transition tax on untaxed foreign earnings of foreign subsidiaries of U.S. companies by deeming those earnings to be repatriated. Certain corporations must now increase their subpart F income by the amount of their deferred foreign income. Code Sec. 965, enacted as part of the TCJA, contains a loophole that allows taxpayers to convert such income so it becomes taxable at 8% (instead of the original 15.5%). This applies to the last tax year that began before Jan. 1, 2018.