PRIOR TO THE ENACTMENT of the Tax Cuts and Jobs Act, the United States was one of the few developed nations operating on a worldwide system of taxation. This tax regime, coupled with some of the highest statutory corporate tax rates in the world, created a far less attractive business environment for U.S. companies operating in an increasingly global economy. With little incentive to bring foreign earnings back to the United States for reinvestment, many American companies retained foreign earnings offshore to avoid paying U.S. taxes imposed upon repatriation. In an effort to incentivize U.S. companies to repatriate foreign earnings and increase U.S. investment and job growth, the new tax reform adopts a modified territorial tax regime, effective for the 2018 and subsequent tax years. This new system of taxation provides a 100 percent exemption from U.S. corporate taxation for dividends received by a 10 percent U.S. corporate shareholder from certain foreign corporations.In preparation for this transition to a modified territorial tax regime, the new tax law provides for a mandatory repatriation tax (&ldquo;toll tax&rdquo;) imposed upon undistributed previously taxed foreign earnings and profits, effective for tax years of foreign corporations beginning before Jan. 1, 2018. All 10 percent U.S. shareholders of foreign corporations with positive pre-2018 accumulated E&amp;P must include in income this E&amp;P amount, subject to U.S. tax at reduced rates. The toll tax is payable over eight years at the taxpayer&rsquo;s election. It is important to note that, in contrast to the 100 percent dividend exemption applicable only to U.S. corporate shareholders, the toll tax applies to all U.S. shareholders.S corporation shareholders, however, may elect to defer the toll tax until a triggering event occurs. For calendar year foreign corporations, the toll tax (or first installment if eight-year payout is elected) must be paid with the 2017 tax return, without regard to extensions. When the E&amp;P subject to the toll tax are actually distributed to the U.S. shareholders in 2018 and subsequent years, they will not be subject to U.S. tax a second time.

The Toll Tax

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Girish Ramdas is the Co-founder and CEO of Magzter, a New York based startup that has been making waves in the global digital publishing business. Magzter has crossed 80 million users since its inception in 2011 from more than 150+ countries with 1000s of magazines, newspapers and books from more than 4,500 publishers worldwide. He has more than 25 years of experience in cross-platform publishing, including print, mobile, and Web development. During this period, he has co-founded and run three successful start-up businesses. He has enabled magazine companies to go digital and helps them monetize their content across the digital world. Girish's deep industry experience in online, mobile and publishing ecosystems has made him an expert in acquisition, marketing and monetizing digital content across platforms globally.

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Magzter Inc. is the World's largest and fastest growing self-service, cross-platform digital newsstand with over 80 million users since its inception in 2011 and thousands of magazines and newspapers across 40+ categories and 60+ languages. Headquartered in New York, Magzter has its local presence in Amsterdam, London, Mexico City, Chennai, Mumbai, New Delhi, Bengaluru, Singapore, and will soon be expanding to other countries. Founded by global entrepreneurs, Girish Ramdas and Vijay Radhakrishnan in June 2011, Magzter enables magazine and newspaper publishers around the world to create and deliver digital editions of their titles to global consumers.

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Magzter offers the world’s largest {{allyoucanread}} subscription service called {{gold}} which gives digital readers unlimited access to 8,500+ magazines and newspapers for a monthly subscription price. Magzter also has the largest number of stories in the world with its game-changing ezRead 2.0 feature for its apps, which enables smartphone and small-screen mobile users to enjoy magazine content the way it was meant to be enjoyed, with article text that is easy to read and is accompanied by stunning videos and high resolution photography.

Magzter offers the world’s largest “All-You-Can-Read” subscription service called Magzter GOLD which gives digital readers unlimited access to 8,500+ magazines and newspapers for a monthly subscription price. Magzter also has the largest number of stories in the world with its game-changing ezRead 2.0 feature for its apps, which enables smartphone and small-screen mobile users to enjoy magazine content the way it was meant to be enjoyed, with article text that is easy to read and is accompanied by stunning videos and high resolution photography.

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Prior to Magzter, he was the President of Dot Com Infoway (DCI) and Galatta Media. His duties included strategic marketing, partnership development, and monetizing content globally. DCI grew from a small team of 3 in 2000 to 300 by 2011 and was dealing with web, software and app development for clients globally.

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is the World's largest and fastest growing self-service, cross-platform digital newsstand with over 87 million users since its inception in 2011 and thousands of magazines and newspapers across 40+ categories and 60+ languages. Headquartered in New York, Magzter has its local presence in Amsterdam, London, Mexico City, Chennai, Mumbai, New Delhi, Bengaluru, Singapore, and will soon be expanding to other countries. Founded by global entrepreneurs, Girish Ramdas and Vijay Radhakrishnan in June 2011, Magzter enables magazine and newspaper publishers around the world to create and deliver digital editions of their titles to global consumers.

n. We will also use usage information in order to ensure users adhere to our Terms of Use. For example, a user’s usage information will help us confirm that a user only downloads a magazine or other content a permitted number of times or to a permitted number of devices.

which gives digital readers unlimited access to 8,500+ magazines and newspapers for a monthly subscription price. Magzter also has the largest number of stories in the world with its game-changing ezRead 2.0 feature for its apps, which enables smartphone and small-screen mobile users to enjoy magazine content the way it was meant to be enjoyed, with article text that is easy to read and is accompanied by stunning videos and high resolution photography.

{{magzter}} is the World's largest and fastest growing self-service, cross-platform digital newsstand with over 87 million users since its inception in 2011 and thousands of magazines and newspapers across 40+ categories and 60+ languages. Headquartered in New York, Magzter has its local presence in Amsterdam, London, Mexico City, Chennai, Mumbai, New Delhi, Bengaluru, Singapore, and will soon be expanding to other countries. Founded by global entrepreneurs, Girish Ramdas and Vijay Radhakrishnan in June 2011, Magzter enables magazine and newspaper publishers around the world to create and deliver digital editions of their titles to global consumers.