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

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Description

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.

Details

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