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 changes.

$$ Create a scenario reflecting the taxation under the prior tax and current law to support your recommendations.