Tax Reform

Tax Reform 

Tax reform continues to come into focus since the signing of the Tax Cuts and Jobs Act (TCJA). As additional regulations and corrections are released, we are closely following developments large—international global intangible low-taxed income (GILTI) and base erosion and anti-abuse tax (BEAT) minimum tax provisions—and small—drafting errors and technical corrections.

When Congress moved on tax reform, Alston & Bird was dedicated to keeping clients informed as the legislation came together. On December 22, 2017, President Trump signed the TCJA into law, the first major tax overhaul in 31 years. In late 2018, the IRS and Treasury began releasing a host of TCJA-related regulations and other guidance that have important implications for taxpayers. We continue to provide insight on how this historic legislation could affect your bottom line. Our team has been actively advising clients on the issues:

Federal & International Tax

  • Tax planning for C corporations versus LLCs and other types of entities, particularly when foreign business activities are involved.
  • Advising a public German manufacturer/importer of medical devices on its financing issues as a result of the new limitation on interest deduction provisions of the TCJA.
  • Advising a foreign multinational finance company on its ability to deduct related party interest under the new BEAT provisions of the TCJA.
  • Advising a foreign investment management company on the effects of the new controlled foreign corporation (CFC) downward attribution rules on its U.S. owners.
  • Advising taxpayers on the impact of the new limitations on the deductibility of interest under Section 163(j).

State & Local Tax

The states’ conformity to key provisions of the TCJA, including interest expense deductions, GILTI, BEAT, and federal NOL provisions.

Wealth Planning

  • Advising individuals and families on the revised standard, whether to itemize, and the end of the “Pease limitation.”
  • Tax planning for individuals with closely held businesses and other types of entities, particularly when foreign business activities are involved.
  • Advising on all the legal and planning issues that go along with high net worth (for those still subject to estate and gift taxes).
  • Helping clients make the most of these changes to promote their philanthropic goals.

Employee Benefits & Executive Compensation

  • Advising clients on the changes to the limitation of deductible compensation for publicly traded and other types companies.
  • Advising clients on the new excise tax (Section 4960) for tax-exempt entities related to excess compensation.
  • Monitoring the changes to rules on participant repayment of 401(k) loans after termination of employment.
  • Advising on changes to deductions for certain fringe benefits.

Check back often as we continue to update how the TCJA can affect estate taxes, pass-through entities, and corporate taxes, plus any trickle-down effects we may see. If you’d like to receive updates directly to your inbox, sign up here.




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Tax Reform Thought Leaders

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