Business-Related Provisions of the 2017 Tax Cuts and Jobs Act breaks down and discusses the impact of many of the complex provisions of the 2017 Tax Cuts and Jobs Act (the “TCAJA”) on domestic and international business operations of C corporations, S corporations, and partnerships. The article is organized in ten sections as follows:

  1. Introduction
  2. The individual “Rate Structure Changes” for both ordinary income and capital gains
  3. The corporate rate structure changes, including the individual tax on dividends and the dividends received deduction
  4. New Section 199A, which provides for a deduction for certain flow-through business income of sole proprietorships, partnerships, and S corporations
  5. A “First Take” on the impact of the TCAJA on the choice of form decision for domestic operations: C corporation, or flow-through entity
  6. The new limitation on the deduction for business interest;
  7. The treatment under the TCAJA of carried interest, that is, profits interest earned by certain hedge fund and private equity managers
  8. Several significant changes impacting both individuals and corporations: (1) the depreciation rules, (2) the Section 179 deduction, (3) changes to the net operating loss deduction, (4) the limitation on excess business losses of an individual, and (5) changes to the like kind exchange provision, Section 1031
  9. Several changes in the international tax arena, including (1) the adoption of a territorial system, (2) the tax on the elimination of the deferral benefit, (3) the taxation of foreign high return amounts, (4) the anti-base erosion rules, and (5) restrictions on income shifting through transfers of intangibles
  10. A “First Take” on the TCAJA’s impact on the domestic M&A, that is, (1) taxable asset acquisitions, (2) taxable stock acquisitions, and (3) acquisitive reorganizations
Publication Date: May 2018
Last Updated: May 2018
ISBN: 9781402411526
Page Count: 110 pages
Number of Volumes: 1

You May Also Like