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The North America Tax Practice group provides updates on US Tax Reform and focuses on how the TCJA affects businesses in their February issue of Tax News and Developments.  Topics include, new guidance on Section 965, corporate income tax rates, Subpart F and more.

In this Issue:

  • Preface: Tax Reform in Congress Gives Way to Implementation, Additional Questions
  • IRS Issues Repatriation Tax Guidance Under New Law
  • Congress Reforms System to Make United States More Competitive Through Reduced Rates, Immediate Expensing, Shift to Territorial System, and IP Carrot (and Stick)
  • “Not GILTI” - Changes to Subpart F Under the New “Territorial” Regime Other Than the Addition of Section 951A
  • Provisions Targeting “Base Erosion”: The BEAT and Other Deduction Limiting Rules
  • Passthrough Tax Changes Under TCJA
  • Transfer Tax/Code Section 482 Implications of TCJA Including Outbound Intellectual Property Transfers to Foreign Subsidiaries
  • TCJA Raises New Opportunities and Traps for M&A Deals 
  • State Corporate Income Tax Considerations of the Tax Cuts and Jobs Act
  • EU Considers Impact of US Tax Reform
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