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

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"