Does that transition to a territorial system apply only to corporations or do individuals count too? American expats are among the few in the world who have to pay taxes to the mothership no matter how long they live abroad.
If you have income from multiple sources, some of which may be in the U.S. and some not, even if it's as simple sideline business, then it gets more complicated as you also have to calculate profit/loss for that as if it were in the U.S., then subtract your taxes paid in your country, and demonstrate that it's all below a certain threshold. And there's also payroll tax exemptions, etc.