Wednesday, March 14, 2018

Liberty Global plc Discloses the Incredible Difficulty in Computing the Trump Tax Cuts Act's Mandatory Repatriation Tax

Here's the relevant part regarding the Trump Tax Cuts Act Mandatory Repatriation Tax contained in Liberty Global plc's Income Tax Footnote in its 10-K 2017 Annual Report filing with the US SEC:

"The Mandatory Repatriation Tax requires that the aggregate post -1986 earnings and profits of our foreign corporations be included in our U.S. taxable income. The one-time repatriation of undistributed foreign earnings and profits is then taxed at a rate of 15.5% for cash earnings and 8% for non-cash earnings, both as defined in the 2017 U.S. Tax Act. Given the amount of information we are required to gather and analyze and the complexity involved in applying the new tax laws in our circumstances, we are currently unable to make a reasonable estimate of any Mandatory Repatriation Tax that we may ultimately incur. Accordingly, we have not yet recorded a Mandatory Repatriation Tax liability in our consolidated financial statements. If we ultimately conclude that we are responsible for a Mandatory Repatriation Tax, our effective tax rate will be negatively affected. Any such Mandatory Repatriation Tax could be material. Our evaluation of these amounts will be finalized during 2018."