Infamous words, spoken by Clint Eastwood in the film ‘In the Line of Fire’ resonate with me at times like this. A tsunami of change is coming. As it bears down on us, my fellow tax professionals, I ask: Have you done all that you can to prepare? What do you see when you are in the dark and the demons come?

In the international tax arena, the scariest demon that has been keeping us on our toes in this time of great tax uncertainty is foreign earnings. Foreign earnings, heretofore sheltered from true US tax analysis by the cloak of protection that is APB 23, are suddenly, seemingly, about to be extraordinarily relevant.