Halifax Inc. operates its business in Country U through a subsidiary incorporated under Country U law. The subsidiary has never paid a dividend and has accumulated more than $10 million after-tax earnings.

a. Country U has a 20 percent corporate income tax. Describe the tax consequences to Halifax if it receives a $5 million dividend from the subsidiary in a tax year prior to 2018.

b. Describe the tax consequence of the subsidiary's pre-2018 unrepatriated earnings as a result of the Tax Cuts and Jobs Act.