The Tax Cuts and Jobs Act: A Practitioner's Resource

The Tax Cuts and Jobs Act: A Practitioner's Resource

Tax Notes is proud to present a resource for practitioners wrestling with the Tax Cuts and Jobs Act. Contributing editor Carrie Brandon Elliot has written a collection of articles that offers a thorough explanation of topics such as foreign tax credits, subpart F, PFICs, hybrids, and the implications for partnerships and consolidated groups.


This collection contains the following articles:

  • "The TCJA's Effect on Foreign Tax Credits"
  • "How the TCJA Has Changed Subpart F"
  • "The TCJA's Effect on PFICs and Controlled Foreign Corporations"
  • "The TCJA and Capital Gains"
  • "The TCJA and Indefinite Reinvestment Assertions"
  • "The TCJA and U.S. Real Estate Investments by Foreign Persons"
  • "The TCJA and Passive Income: Mixed Incentives"
  • "The TCJA's New Revenue Recognition Timing Test"
  • "The TCJA's Tax Accounting Challenges"
  • "The TCJA's Fourth-Quarter Playbook for Filers"
  • "The TCJA's Effects on Oil and Gas Investments"
  • "The TCJA's Bargain With Insurance Companies"
  • "The TCJA and Partnerships"
  • "TCJA Tax Rate Increases to Begin in 2019"
  • "The TCJA Brings Big Changes to Tax Accounting"
  • "Reducing TCJA Accounting Distortions"
  • "New TCJA-Related Regs Ease Double Counting and Income Mismatches"
  • "TCJA and Effectively Connected Income Deduction Limits"
  • "The TCJA and New FTC Limitation Rules"
  • "How GILTI Discourages Research in the United States"
  • "Expanding Hybrid Deduction Accounts to GILTI and Subpart F"
  • "How Imported Mismatch Payment Rules Can Create Double Taxation"
  • "TCJA Hybrid Regulations: Overreach or Underdone?"
  • "Extending TCJA Section 267A to Reverse Hybrids"
  • "Stretching Interest Disallowance Applicability in Section 267A"
  • "Navigating TCJA Foreign Tax Credit Limitations"
  • "How Section 245A Temporary Regs Limit Dividends Received Deductions, Part 1"
  • "How Section 245A Temporary Regs Limit Dividends Received Deductions, Part 2"
  • "How Sections 245A and 964(e)(4) Coordinate Treatment of Dividends"
  • "Proposed New Regs Allow GILTI Exclusion for CFC High-Taxed Income"
  • "Election to Consolidate Can Affect Transition Tax Liability"
  • "Consolidated Groups Face Challenges From Proposed 163(j) Regs"
  • "Consolidated Groups Wrestling With the BEAT"
  • "Consolidated Group Members Become Single Under GILTI"
  • "Consolidated Groups Weigh GILTI Effect on Basis Adjustments"
  • "Consolidated Groups Seek Deductions Under Proposed FDII and GILTI Regs"
  • "Consolidated Groups Still Facing Hybrid and DCL Problems"
  • "A New Hybrid Approach for Partnerships in GILTI and Subpart F Regs"
  • "Reducing GILTI Inclusion by Capitalizing or Apportioning Depreciation"
  • "Using an Aggregate Approach to Determine Partnership QBAI"
  • "Antiavoidance Rules Thwart Reduced GILTI Inclusions"
  • "How Qualified Interest Income and Expense Can Affect GILTI Inclusions"
  • "Inventory Your Cost of Goods Sold to Minimize the BEAT"
  • "Preventing Double Nontaxation: Subpart F and GILTI Coordination"
  • "Clarifying TCJA Insurance Provisions in Proposed PFIC Regs"
  • "Proposed BEAT Regs Clarify Aggregate Group Rules"
  • "Beat the BEAT: Waiving Base Erosion Deductions"
  • "Beat the BEAT, Part 2: Partnership Antiabuse"
  • "Tweaking Old Expense Rules for New TCJA Realities"
  • "New Regs Address High-Taxed Exceptions When Foreign Tax Reduced"
  • "Navigating New Foreign Income Tax Allocation and Apportionment Regs"
  • "Proposed Regs Allow Some Loss Recapture to Affect FTC Limitation"
  • "Clarifying the Consolidated FTC Limitation Computation"
  • "Clarifying Subpart F and GILTI Inclusions for Indirect and Deemed Paid Taxes"
  • "Regs Increase Fractions Limiting FTC Deemed Paid Taxes"
  • "New Inclusion Requirements for Deemed Paid Tax Calculations"
  • "Regs Allow FTC Limitation Adjustments For GILTI Distributions"
  • "How Disregarded Transactions Can Alter the FTC Limitation"
  • "Section 904 Regs’ Further Clarify Foreign Branch Income Category"
  • "New GILTI High-Tax Regs Introduce Tested Units"
  • "New GILTI High-Tax Regs Address Disregarded Payments"
  • "New Regs Address High-Tax GILTI Election"
  • "Proposed Regs Modify Effective Foreign Tax Rate Calculation"
  • "Proposed High-Tax Regs Introduce New Subpart F and GILTI Concepts"
  • "Proposed High-Tax Regs Introduce New Documentation Requirements"
  • "Proposed Regs Allow Group Interest Deduction Limitation"
  • "Proposed Regs Give and Take: Safe Harbor and Antiavoidance Rules"
  • "Proposed Regs Clarify 2019, 2020 COVID-19-Related Interest Rules"
  • "Proposed Regs Modify Interest Limitation Formula for Effectively Connected Income"
  • "Final Regs Address Interest Expense Limitation for Partnerships"
  • "Final Regs Provide 11 Steps for Partnerships With Interest Limitation"
  • "Partnership Interest Calculation Includes Conditional Eighth Step"
  • "Proposed Regs Clarify Interest Rules for Tiered Partnerships"
  • "Proposed Regs Clarify Conversion Events for Tiered Partnerships"
  • "Proposed Regs Clarify Dispositions of Tiered Partnership Interests"
  • "Final Regs Limit Disqualified Basis Reduction"
  • "Final Regs Address Multiple Extraordinary Disposition Accounts"
  • "Addressing Exchanged Basis Property and Duplicate Disqualified Basis"
  • "Final Regs Lay Ground Rules for Section 1446(f) Withholding"
  • "Final Regs Allow Six Exceptions to Section 1446(f) Withholding"
  • "Final Regs Allow Adjustments to Section 1446(f) Withholding"
  • "Final Regs Clarify Partnership Withholding Under Section 1446(f)(4)"
  • "Final Regs Clarify Withholding for Publicly Traded Partnerships"
  • "Final Regs Offer Five Exceptions to PTP Withholding"
  • "Final Regs Clarify PTP Withholding on Distributions"

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