Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that date. In the ensuing months, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) have had the monumental task of issuing Treasury Regulations addressing the numerous provisions of the Act. In the meantime, prior to the release of regulatory guidance, corporations and practitioners alike have been grappling with how to implement the modifications to the Internal Revenue Code of 1986, as amended (the “Code”).

The Act was promulgated over 18 months ago, so our focus will be on the key regulatory guidance that has been released in the past year rather than on the provisions of the Act itself.

Originally published by Global Legal Group Ltd, London.