U.S. persons who own 10% or more of the shares of a foreign corporation may need to act quickly on a new rule that can require inclusion of all foreign corporate earnings accumulated after 1986.  This one-time tax obligation applies to 2017 tax returns with respect to earnings of calendar-year foreign companies. The good news is that the tax liability resulting from this provision can be paid over eight years (or in certain cases deferred indefinitely).  However, in order to take advantage of the payment plan, both a timely election and timely first payment are required.