According to the course text, the United States has employed a worldwide system of taxation for the past 100 years. The Tax Cuts and Jobs Act (TCJA) upended this system. Imagine you are an international tax consultant advising a client on the impact of P.L. 115-97, the law known as the Tax Cuts and Jobs Act, on the taxation of a controlled foreign corporation (CFC).

• Analyze two changes to CFCs and advise your client on the actions necessary to reduce current and future tax liability as a result of these charges.
• Create a scenario reflecting the taxation under the prior tax and current law to support your recommendations.