The legislation known as the Tax Cuts and Jobs Act of 2017 (TCJA), P.L. 115-97, imposes a "toll charge" on the mandatory deemed repatriation of certain deferred foreign earnings. As part of the transition to a territorial tax system, amended Sec. 965 uses the mechanics of the current Subpart F provisions to impose a one-time toll tax on the undistributed, non-previously taxed, post-1986 foreign earnings and ...