ContentsInternational Tax Treatment Under Prior and New Law 1Territorial or Worldwide: Basic Rules 1Prior Law: Deferral and the Foreign Tax Credit 2New Law: Dividend Exemption, GILTI, and FDII 4Allocation and Anti-Abuse Rules 6Prior Law: Subpart F; Transfer Pricing; Interest Deductions and ThinCapitalization Rules 6New Law: BEAT, Modifications to Subpart F, Transfer Pricing Changes, StricterThin Capitalization Rules 8Tax Treaties 10Repatriation Rules 11Pri
