While the international provisions of the Tax Cuts and Jobs Act (the TCJA) as well as a handful of domestic provisions, such as Sections 199A and 451, have attracted significant taxpayer attention, the IRS notices on Section 162(m),meals and entertainment, and Section 45S’s credit for family and medical leave have attracted little to no public comments or complaints.

Who would have thought it would be the IRS’ notice on the deduction disallowance under Section 274 for employer parking that would be the guidance that broke the camel’s back and finally brought attention to the regulatory burden being imposed on taxpayers by the compensation-related changes made in the TCJA?


Originally published in the May/June 2019 issue of Corporate Taxation, a journal published by Thomson Reuters.

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