Summary: U.S. outbound tax rules apply to U.S. tax residents (individuals or domestic corporations) when they earn income from abroad. Such income can be earned directly or through a foreign subsidiary. In a sense, this is the opposite of inbound taxation, which governs non-U.S. tax residents earning income from U.S. sources.

Our summary covers the following aspects of U.S. outbound taxation:

–  Foreign derived intangible income (FDII);
–  Taxation of controlled foreign corporations (CFC)- GILTI regime;
–  Taxation of subpart F income;
–  Base Erosion and Anti-Abuse Tax (BEAT)

Our analysis also covers changes introduced by the 2025 tax reform.