The benefits of using a foreign holding company structure after US tax reform depends on the facts involved.
If a particular holding company’s only purpose was to avoid US tax under the previous rules, for example, to enable a freer flow of cash within the foreign corporate structure, perhaps that holding company could now be eliminated from the corporate structure," Fuller said. "However, a holding-company structure might reduce foreign withholding tax on dividends, which could now become costly non-creditable taxes in the US. Using a holding company for this purpose could have continuing benefits,” stated Larissa Neumann and Julia Ushakova-Stein, both partners at Fenwick & West. “A holding company structure also could be used to generate Subpart F income if that’s desirable as a part of the taxpayer’s foreign tax credit planning under the recent Tax Act," said Neumann and Ushakova-Stein.
https://www.tpweek.com/articles/tax-directors-get-to-grips-with-us-tax-reform-and-gilti/arosnjtt
