The U.S. Treasury Inspector General for Tax Administration (TIGTA) issued a final report on 22 May 2019 on the Implementation of the Tax Cuts and Jobs Act, including, in particular, the deemed repatriation (transition) tax on the post-1986 accumulated earnings and profits of foreign corporations. --- IMPACT ON TAXPAYERS On December 22, 2017, the Tax Cuts and Jobs Act (hereafter referred to as the "Act") was enacted into law.  The Act was the most significant revision of the U.S. tax code in more than 30 years, and according to the IRS, implementing the Act is its highest priority. Among its many...