On Friday, December 15, the House-Senate Conference Committee on tax reform agreed to a tax reform bill to be voted on by Congress this week. The stage appears to be set for the most sweeping tax reform legislation since 1986.
This alert highlights some of most significant portions of the bill affecting business and wealth and succession planning.
Conference Committee – Tax Cuts and Jobs Act |
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Corporate Tax Rates & AMT |
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Corporate Dividends Received Deduction |
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Net Operating Losses |
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Cost Recovery / Full Expensing |
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Section 179 Expensing |
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Recovery Period for Real Property |
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Cash Method of Accounting |
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Interest Expense Deduction |
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Pass-Through Taxation |
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Limitation on Deduction of Excess Business Losses |
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Like-Kind Exchanges |
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Carried Interests |
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Partnerships – Technical Termination |
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Partnerships – Basis Limitation on Partner Losses |
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Partnerships – Substantial Built-in Loss |
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Partnerships – Source of Gain or Loss on Sale of Interest |
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Business Credits |
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Bond Reforms |
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Local Lobbying Expenses |
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Domestic Production Activities |
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International Tax Regime |
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Repatriation “Toll Tax” |
100% U.S. corporate shareholders taxed on share of CFC’s previously untaxed foreign E&P:
Proportional reduction in foreign tax credits attributable to previously untaxed foreign earnings |
Controlled Foreign Corporations |
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Foreign Derived Intangible Income |
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Anti-Base Erosion Provisions |
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Estate, Gift and Generation-Skipping Transfer Taxes |
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Net Investment Tax on Private Colleges and University Endowments |
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