Tax Reform

Tax Cuts and Jobs Act (TCJA)

Andersen is staying on top of the latest guidance on tax reform. For all of the most recent information, please refer to the links below. These links include our most recent tax releases as well as charts detailing the various provisions and bills. 

We will continue to keep you up to date as the tax reform process continues to ensure you and your businesses are ready for the potential changes ahead.

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Treasury and IRS Issue Final Regulations on Simplified Tax Accounting Rules for Small Businesses Under the TCJA

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Treasury and IRS Issue Final Income Recognition Rules Under TCJA

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Treasury and IRS Will Respect State Pass-Through Entity Workaround Laws Aimed at Circumventing TCJA’s SALT Deduction Cap

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January 15, 2021

Treasury and IRS Issue Final Regulations on Simplified Tax Accounting Rules for Small Businesses Under the TCJA

Treasury and IRS recently issued final regulations (TD 9942), offering guidance under the various regulations to adopt the simplified tax accounting rules for small businesses under the Tax Cuts and Jobs Act (TCJA). The  Read More

January 12, 2021

Treasury and IRS Issue Final Income Recognition Rules Under TCJA

Final regulations (TD 9941) implementing the income recognition rules enacted under the Tax Cuts and Jobs Act (TCJA) under Sec. 451(b) and (c) were recently released. The final regulations for both provisions include many  Read More

November 13, 2020

Treasury and IRS Will Respect State Pass-Through Entity Workaround Laws Aimed at Circumventing TCJA’s SALT Deduction Cap

Partnerships and S corporations based in a state and local jurisdiction that imposes a mandatory or elective income tax at the entity level are allowed to fully deduct state and local income taxes  Read More

October 08, 2020

Treasury and IRS Release Final Regulations on Gain or Loss of Foreign Persons From the Sale or Exchange of Certain Partnership Interests

Final regulations released by Treasury and IRS offer guidance for foreign persons that recognize gain or loss from the sale or exchange of an interest in a partnership that is engaged in a  Read More

September 11, 2020

Final and Proposed Regulations on Section 163(j) Business Interest Expense Limitation Address Cost Recovery Issues

On July 28, 2020, the Treasury Department released a package of final regulations (TD 9905) (Final Regulations) and proposed regulations (REG-107911-18) (2020 Proposed Regulations) that provide guidance on the business interest expense limitation under Sec. 163(j).  Read More

August 26, 2020

Final Regulations on Section 163(j) Business Interest Expense Deduction Limitation Provide Narrower Definition of Interest

On July 28, 2020, the Treasury Department released a package of final regulations (TD 9905) (Final Regulations) and proposed regulations (REG-107911-18) (2020 Proposed Regulations) that provide guidance on the business interest expense limitation under Internal Revenue  Read More

August 14, 2020

Treasury and IRS Release Long-Awaited Guidance on Carried Interest Rule in Section 1061

On July 31, 2020, Treasury and IRS released proposed regulations regarding Sec. 1061’s carried interest rule, which was enacted as part of the Tax Cuts and Jobs Act (TCJA). Targeting incentive allocations made to  Read More

July 24, 2020

IRS Issues Guidance on GILTI High-Tax Exclusion

Treasury and IRS issued final regulations (T.D. 9902) allowing taxpayers to exclude certain high-taxed income of a controlled foreign corporation (CFC) from their global intangible low-taxed income (GILTI) computation on an elective basis.  Read More

July 22, 2020

Final Regulations Related to GILTI Deduction Provide Potential Benefits for Individuals

IRS and Treasury released final regulations (T.D. 9901) under Sec. 250 of the Internal Revenue Code (Code). The final regulations provide potential benefits for individuals subject to GILTI. Individuals making a Sec. 962 election are  Read More

July 21, 2020

Final Regulations Under Section 250 Offer Additional Clarity for Determining the Foreign-Derived Intangible Income Deduction

IRS and Treasury have released final regulations under Sec. 250 of the Internal Revenue Code (Code). The final regulations adopt the basic structure and approach of the proposed regulations but diverge in several notable  Read More

June 26, 2020

Proposed Regulations Address Elimination of the Deduction of Qualified Transportation Fringe Benefits Under the Tax Cuts and Jobs Act

Treasury and IRS issued proposed regulations implementing the elimination of the deduction by employers of qualified transportation fringe (QTF) expenses under the Tax Cuts and Jobs Act (TCJA) for tax years beginning after 2017.  Read More

May 08, 2020

Taxpayers Face Uncertainty on State Treatment of Interest Expense Deduction for Affiliated Groups

With the second filing season underway after the enactment of the 2017 Tax Cuts and Jobs Act (TCJA) many states have yet to provide guidance on how the TCJA’s business interest expense  Read More

March 02, 2020

New Guidance on Scaled-Back Deduction for Meals and Entertainment Under the TCJA

Proposed regulations explain how to determine whether an activity will be disallowed as an entertainment expense. The proposed rules also address the limitation on the deduction for food and beverages provided at or  Read More

January 29, 2020

Final Regulations Make Key Changes, Add Flexibility and Resolve Some Uncertainties Regarding Qualified Opportunity Zones

Treasury and IRS adopted final regulations related to the Qualified Opportunity Zone (QOZ) program included within the Tax Cuts and Jobs Act (TCJA). The TCJA provided for the qualification of certain low-income census  Read More

January 15, 2020

2019 Year-End Tax Act Provides Retroactive Tax Relief for Tax-Exempt Organizations and Donors

Year-end government funding legislation (H.R. 1865) enacted on December 20, 2019, includes significant tax provisions of interest to tax-exempt organizations. The tax-exempt parking tax was retroactively repealed, entitling tax-exempt organizations who paid the tax to  Read More

December 22, 2019

Proposed Regulations on SALT Cap Workarounds Maintain Focus on State-Created Charities, But Remain Silent on Pass-Through Planning

Treasury and IRS released proposed rules incorporating earlier guidance on the treatment of payments made to charitable organizations in return for tax credits as payments of state or local taxes for federal income  Read More

December 04, 2019

Taxpayers Benefiting from Temporarily Raised Estate and Gift Tax Exclusion Amount Will Not Be Adversely Impacted in Future Years

Individuals taking advantage of the increased gift and estate tax exclusion amounts in effect from 2018 to 2025 enacted under the Tax Cuts and Jobs Act (TCJA) will not be adversely impacted after 2025 when the  Read More

November 08, 2019

IRS Form Instructions Would Reduce the Section 199A Deduction for Charitable Contributions Made by a Business

Draft instructions to both the 2019 Form 8995 and the 2019 Form 8995-A provide additional guidance on computing QBI beyond the scope of guidance in the final regulations  Read More

September 27, 2019

The States’ Evolving Responses to Tax Reform Present Opportunities and Challenges to Business Taxpayers

The states’ responses to the sweeping changes under the Tax Cuts and Jobs Act (TCJA) are as varied as their own unique tax codes. Determining a state’s approach to TCJA  Read More

July 11, 2019

Final GILTI Regulations Include Beneficial Change for Certain Partners in Partnerships That Own CFCs

Under final regulations, GILTI inclusions are not determined at the partnership level—domestic partnerships are instead treated as an aggregation of their partners for purposes of GILTI.  Read More

May 30, 2019

New Excise Tax on Executive Compensation May Entrap For-Profit Entities

New Sec. 4960 imposes a 21% excise tax on compensation in excess of $1 million, or any excess parachute payment paid, to a covered employee of a tax-exempt organization.  Read More

April 24, 2019

Treasury Issues Additional Proposed Regulations on Qualified Opportunity Zones

On April 17, 2019, Treasury and IRS released a second set of proposed regulations (the New Proposed Regulations) with respect to Qualified Opportunity Zones (QOZs). The New Proposed Regulations clarify a number of requirements for  Read More

February 14, 2019

Blue Book Sheds Light on New NOL Deduction and Carryover Losses

The Tax Cuts and Jobs Act (TCJA) did not explain how a taxpayer with both net operating loss (NOL) carryforwards from taxable years before and after the TCJA effective date should apply the  Read More

December 26, 2018

IRS Issues Interim Guidance for Tax-Exempt Employers on Parking Fringe Expenses

IRS has issued two notices to address the tax treatment of qualified transportation fringe benefits, as modified by the Tax Cuts and Jobs Act (TCJA).  Read More

December 26, 2018

IRS Issues Interim Guidance for Employers on Parking Fringe Expenses

IRS has issued a notice to address the tax treatment of qualified transportation fringe benefits, as modified by the Tax Cuts and Jobs Act (TCJA).  Read More

December 20, 2018

Qualified Opportunity Zones – Regulatory Guidance Clears the Path for Investors

The Tax Cuts and Jobs Act (TCJA) codified new tax incentives aimed at attracting investment into low-income communities and certain contiguous areas certified by Treasury as qualified opportunity zones (QOZs). Taxpayers that  Read More

September 13, 2018

Tax Reform - IRS Issues Guidance on New UBTI Rules for Separate Trades or Businesses

IRS has issued Notice 2018-67 (the Notice) to provide guidance on the calculation of unrelated business taxable income (UBTI) for tax-exempt organizations following tax reform. The Tax Cuts and Jobs Act (TCJA) changed  Read More

August 21, 2018

The New Foreign-Derived Intangible Income (FDII) Deduction

The Tax Cuts and Jobs Act (TCJA) presented a significant change to the international tax regime. Among the changes was the introduction of a new special deduction for domestic C corporations for Foreign-Derived  Read More

August 08, 2018

Guidance Released on New 20% Pass-Through Deduction; Includes Aggregation Election

IRS and Treasury have released the first set of proposed regulations related to the new 20% deduction for qualified business income under Sec. 199A, enacted as part of the Tax Cuts and Jobs Act  Read More

August 02, 2018

Treasury Issues Regulations on Transition Tax on Foreign Earnings

Treasury and IRS have issued proposed regulations related to the new mandatory deemed repatriation under Sec. 965 (the Transition Tax). The proposed rules include additional guidance and definitions that are useful for many taxpayers.  Read More

July 30, 2018

IRS Clarifies Effect of Suspended Miscellaneous Itemized Deductions on Trusts and Estates

IRS has announced in Notice 2018-61 (the Notice) that it will issue regulations to clarify that trusts and estates will be allowed to take deductions for expenses that are unique to trust and  Read More

July 24, 2018

The New Global Intangible Low-Taxed Income (GILTI) Regime

The Tax Cuts and Jobs Act (TCJA) introduced an entirely new taxing regime under U.S. federal tax law, known as the global intangible low-taxed income (GILTI) regime.   Read More

May 16, 2018

Tax Reform – Blended Rate for Fiscal Year Taxpayers (Regular and AMT)

The Tax Cuts and Jobs Act (TCJA) replaced the previous graduated corporate tax rate structure (top rate of 35%) with a flat tax rate (21%) and repealed the alternative minimum tax (AMT)for corporations for  Read More

April 09, 2018

Tax Reform - Qualified Opportunity Zones: Opportunity to Defer and Potentially Eliminate Tax on Gains

The Tax Cuts and Jobs Act (the TCJA) provides a new tax benefit starting on December 22, 2017 that is aimed at attracting investments in low-income communities and some surrounding census tracts certified by  Read More

March 22, 2018

Accounting Methods Update: Changes to Tax Rules Affecting Businesses and Individuals

Click here to read about some of the legislative changes made by the Act and the impacts of the new provisions as they relate to accounting method considerations.  Read More

February 09, 2018

Tax Reform Act of 2017 – Highlights of the Key Items

The following charts set forth some of the provisions in the Tax Reform Act of 2017 and offer insights from Andersen’s technical experts. The charts highlight only some of the key issues  Read More

January 17, 2018

Tax Reform – Impact on Financial Reporting

Click here for information regarding some of the accounting for income tax considerations related to key provisions in the final tax reform legislation.   Read More

January 04, 2018

Updated: The Impact of the New Tax Reform Legislation on Business Real Estate and Partnerships

Click here to read more about the impact of the new tax reform legislation on business real estate and partnerships.  Read More

December 22, 2017

Updated: Tax Reform – Effects on Inbound Foreign Investment

With the passage of the Tax Cuts and Jobs Act (the Act) into law, it is appropriate to now attempt to evaluate the effects of the reform on the tax planning for inbound  Read More

December 20, 2017

Tax Reform – Year-End Planning for Individuals and Trusts

The House and Senate have voted to approve the compromise tax reform bill and final tax reform legislation is headed to President Donald Trump for his signature.  Read More

December 02, 2017

Senate Approves Tax Bill in Race to Enact Tax Reform by Year End

Senate Republicans voted early Saturday morning to approve the Senate’s version of the Tax Cuts and Jobs Act with a vote of 51-49 on a party line vote. Bob Corker was  Read More

December 08, 2017

Tax Reform – Effects on Inbound Foreign Investment

Click here to view information regarding the effects on inbound foreign investment.   Read More

November 30, 2017

House and Senate Tax Reform Proposals – Highlights of the Key Issues

The following charts set forth some of the provisions in the Tax Cuts and Jobs Act. The House version of the Tax Cuts and Jobs Act was approved by the House  Read More

November 17, 2017

House Passes and Senate Finance Committee Advances Landmark Tax Reform Legislation

The House passed its version of the Tax Cuts and Jobs Act on November 16, 2017, along a mostly party-line vote of 227-205, with 13 Republicans voting no along with every Democrat. The Senate Finance Committee  Read More

November 03, 2017

House Releases Draft Tax Reform Legislation to Overhaul Tax Code

On November 2, 2017, the House Committee on Ways and Means Chairman Kevin Brady (R-Texas) released the latest piece in the tax reform puzzle—a draft bill to overhaul the tax code. The Tax  Read More

October 26, 2017

House Approves Senate Budget, Puts Tax Reform on Fast Track

On October 26, 2017, the House of Representatives approved the budget resolution previously passed by the Senate less than a week before. The House’s slim party-line vote (216-212) on a compromise budget eliminates  Read More

October 20, 2017

Senate Approves Budget Setting Stage for Release of Tax Reform Details

The Senate approved its fiscal year 2018 budget resolution the evening of October 19, 2017 on a largely party-line vote of 51-49, with a vote against from Republican Senator Rand Paul (R-KY). The House of Representatives  Read More

September 28, 2017

Republicans Release Unified Framework for Tax Reform, Open Door to Tax Increase on Wealthy

On September 27, 2017, The Trump Administration, House Committee on Ways and Means, and Senate Finance Committee released a nine-page Unified Framework for Fixing Our Broken Tax Code (Unified Framework) that specifies a proposed tax  Read More

August 18, 2017

Republicans Pitch Tax Reform to the American People

Former President Ronald Reagan signed the Tax Reform Act of 1986 on August 16, 1986. Now, over three decades later, Ways and Means Chairman Kevin Brady made his pitch for tax reform from Reagan’s  Read More

August 01, 2017

August Has Arrived, But Tax Reform Details Remain Scarce

After months of closed-door meetings on tax reform, the Big Six—a working group of Republican leaders that includes Secretary of Treasury Steven Mnuchin, National Economic Council Director Gary Cohn, Speaker of  Read More

November 30, 2017

Alternative Investment Funds: Tax Proposals Impact But Do Not Dampen Their Use: An Update

Click here to view additional information regarding how investment funds are affected by each bill.   Read More

November 30, 2017

Tax Reform Planning for Multinational Corporations

Click here to read more about how Andersen can help multinational corporations prepare for tax reform.  Read More