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