US Tax Reform Roadmap

Mayer Brown Analysis: The Public-Private Partnership Infrastructure Exception to the Internal Revenue Code Section 163(j) Interest Deduction Limitation

Mayer Brown Analysis: General Explanation of Public Law 115-97

Mayer Brown Analysis: Treasury Adds Color to Grecian Repeal – Proposed Regulations Implement New Section 864(c)(8) for Sale of Partnership Interests by Foreign Partners

Mayer Brown Analysis: IRS Releases Proposed Anti-Hybrid Regulations

Sections 1441 and 1461, FATCA

IRS Issues Proposed Regulations Reducing Burdens Under FATCA, Chapter 3

Official Document: REG-132881-17

Mayer Brown Analysis: Treasury Releases Proposed Regulations on Foreign Tax Credits under New International Tax Rules

Section 959

IRS Issues Guidance on Previously Taxes Earnings and Profits

Official Document: Notice 2019-1

Section 59A

IRS Issues Proposed Regulations on Base Erosion and Anti-Abuse Tax

Official Document: REG-104259-18

Section 83(i)

IRS Issues Guidance on Tax Benefit for Stock Options and Restricted Stock Units

Official Document: Notice 2018-97

Section 904

IRS Issues Proposed Regulations on Foreign Tax Credits

Official Document: REG-105600-18

Section 163(j)

IRS Issues Proposed Regulations on Business Interest Expense Deduction Limit

Official Document: REG-106089-18

Mayer Brown Analysis: High-Level Overview of the Proposed Regulations on Interest Deduction Limitation Rules

Section 956

IRS Issues Proposed Regulations Reducing Income Inclusions for Certain CFC Shareholders

Official Document: REG-114540-18

Mayer Brown Analysis: Proposed Regulations Change Calculus of Section 956’s “Deemed Dividend” for US Corporate Shareholders

Section 1400Z-2

IRS Issues Proposed Regulations on New Opportunity Zone Tax Incentive

Official Document: REG-115420-18

Mayer Brown Analysis: Window of Opportunity: The IRS Issues Initial Guidance on Qualified Opportunity Zone Rules

Section 274

IRS Issues Guidance on Tax Cuts and Jobs Acts Changes on Business Expense Deductions for Meals, Entertainment

Official Document: Notice 2018-76

Mayer Brown Analysis: Tax Reform Income Acceleration Provision Inapplicable to Accrued Market Discount

Section 451(b)

IRS Intends to Issue Proposed Regulations on Market Discount

Official Document: Notice 2018-80

Mayer Brown Analysis: Tax Reform Income Acceleration Provision Inapplicable to Accrued Market Discount

Mayer Brown Analysis: Can You Simply Remove GILTI Income from Your State Tax Base (New York and Elsewhere)?

Section 199A, 643

IRS Issues Proposed Regulations on New 20 Percent Deduction for Passthrough Businesses

Official Document: REG-107892-18

Section 168(k)

IRS Issues Proposed Regulations on New 100 Percent Depreciation

Official Document: REG-104397-18

Mayer Brown Analysis: Gain Deferral Using Qualified Opportunity Zone Investment Strategies

Section 965

IRS Issues Proposed Regulations Implementing Section 965

Official Document: REG-104226-18

Mayer Brown Analysis: New Jersey: Huge Tax Increase Pending

Section 164

IRS Issues Notice on State and Local Tax Deductions

Official Document: Notice 2018-54

Mayer Brown Analysis: IRS to Propose Regulations on Certain States' SALT Deduction Charitable Contribution Workaround

Mayer Brown Analysis: IRS Previews Life Settlement Reporting Regulations

Section 6050Y

IRS Describes New Tax Reform Information Reporting Requirements for Certain Life Insurance Contract Transactions and Provides Transitional Guidance Delaying Reporting until Final Regulations are Issued

Official Document: Notice 2018-41

Mayer Brown Analysis: IRS Previews Life Settlement Reporting Regulations

Section 965

IRS Issues Additional Guidance on Transition Tax on Foreign Earnings

Official Document: Notice 2018-26

Section 163(j)

IRS Issues Guidance on Business Interest Expense Limitations

Official Document: Notice 2018-28

Mayer Brown Analysis: New Guidance on Interest Deduction Limitation Under Section 163(j)

Section 1446(f)

IRS Issues Guidance on Withholding on the Transfer of Partnership Interests by Foreign Persons

Official Document: Notice 2018-29

Mayer Brown Analysis: The Impact of Tax Reform on Leveraged Lending Transactions

Section 1061

IRS Announces Carried Interest Limitations Apply to S Corps

Official Document: Notice 2018-18

Sections 442 and 951

IRS Issues Guidance on Accounting Period Changes Under Transition Tax

Official Document: Rev. Proc. 2018-17

Sections 1400Z-1 and 1400Z-2

IRS Issues Guidance on Nomination Process for Qualified Opportunity Zones

Official Document: Rev. Proc. 2018-16

Joint Committee on Taxation Releases Overview of 2018 Federal Tax System

Official Document: Overview of the Federal Tax System as in Effect for 2018

Mayer Brown Analysis: The Tax Act Changes the Game for Transfer Pricing

Mayer Brown Analysis: The Impact of Tax Reform on Securitization and Other Financing Transactions - What You Need to Know

Section 54C

IRS Withdraws New Clean Renewable Energy Bond Solicitations

Official Document: Notice 2018-15

Sections 3402 and 3405

IRS Extends Withholding-Exemption Period

Official Document: Notice 2018-14

Section 965

IRS Issues Additional Guidance on Transition Tax on Foreign Earnings

Official Document: Notice 2018-13

Mayer Brown Analysis: The Impact of Tax Reform: What Equipment Leasing Companies Need to Know

Section 3401

IRS Releases 2018 Income Tax Withholding Tables Reflecting Tax Reform Changes

Official Document: Notice 1036

Mayer Brown Analysis: How the Tax Cuts and Jobs Act Will Impact Outsourcing

Section 965

IRS Issues Guidance on Transition Tax on Foreign Earnings

Official Document: Notice 2018-07

Sections 864 and 1446

IRS Issues Guidance Suspending Withholding for Dispositions of PTP Interests

Official Document: Notice 2018-08

Joint Committee on Taxation Releases a Dynamic Score of Conference Agreement

Official Document: JCT's Macroeconomic Analysis of Conference Agreement

President Trump Signs the Tax Bill into Law

Mayer Brown Analysis: "The Good, the Bad and the Ugly"—Fundamental Tax Reform Is Enacted Into Law

Mayer Brown Analysis: Government Settlements - Tax Reform Brings New Restrictions on Deductibility

Mayer Brown Analysis: SEC Staff Issues Guidance on Accounting and Reporting Impacts of Tax Cuts and Jobs Act

House Votes Again (224 to 201) to Pass the Modified Tax Bill

Official Document: Enrolled Bill

Senate Votes (51 to 48) to Pass the Tax Bill (with minor modifications)

Official Document: Senate Amendment

House Votes (227 to 203) to Pass the House-Senate Tax Bill

Conference Committee Releases House-Senate Tax Bill

Official Document: Tax Bill and Explanation

Official Document: Joint Committee on Taxation's Estimated Budget Effects and Distributional Effects of the Conference Agreement

Mayer Brown Analysis: 2018 and Onward: The Impact of the House-Senate Compromise Tax Plan on the Renewable Energy Market

Republican Leaders Reach an Agreement to Settle Differences Between the House- and Senate-Passed Bills

Joint Committee on Taxation Releases a Dynamic Score of House-Passed Tax Plan

Official Document: JCT's Macroeconomic Analysis of House Bill

Joint Committee on Taxation Releases Comparisons of the House- and Senate-Passed Tax Plan

Official Document: JCT Comparison of provisions of the bills

Official Document: JCT Comparison of revenue effects of the bills (released 12/11/2017)

Senate Votes to Set Up the Conference Committee (51-47)

House Votes to Form the Conference Committee (222 to 192)

Senate Passes Senate Tax Plan on a 51–49 Vote

Official Document: Joint Committee on Taxation's Estimated Revenue Effects of Senate-Passed Tax Plan

Official Document: Tax Bill (substitute amendment) as passed by Senate

Mayer Brown Analysis: Senate Bill Passage Takes Tax Reform One Step Closer to Reality

Mayer Brown Analysis: Senate's Tax Bill's Impact on the Tax Equity Market: Five Differences from the House Bill

Senate Releases Tax Bill Amendment Before the Vote

Official Document: Tax Bill Amendment

Official Document: Joint Committee on Taxation's Estimated Revenue Effects of Modified Senate Tax Plan

Joint Committee on Taxation Releases a Dynamic Score of Senate Tax Plan

Official Document: Joint Committee on Taxation's Macroeconomic Analysis of Senate Bill

Senate Votes to Open Debate on Senate Tax Plan (52 to 48)

Official Document: Tax Bill (revised) as considered by Senate

Senate Finance Committee Approves Senate Tax Plan

Official Documents: Joint Committee on Taxation's Estimated Revenue Effects of Senate Tax Plan and Distributional Effects of Senate Tax Plan

Official Document: Tax Bill as reported to the Senate floor

Official Document: Section-by-Section Summary

House Passes Tax Bill

Official Document: Tax Bill as passed by House

Official Document: Section-by-Section Summary

Official Documents: Joint Committee on Taxation's Estimated Revenue Effects and Distributional Effects of House Bill

Mayer Brown Analysis: A Sisyphean Task: The House of Representatives Passes Tax Reform Legislation

Senate Finance Committee Chairman Hatch Releases Modifications to Senate Tax Plan

Official Document: Additional comments from Chairman Hatch (corrected rate tables)

Official Documents: Joint Committee on Taxation's Estimated Revenue Effects and Distribution Effects of the Chairman's Amendment to Senate Tax Plan

Mayer Brown Analysis: The Drama Continues: Senate Finance Committee Chairman's Mark Includes Proposals That Would Dramatically Impact Executive Compensation Programs

House Ways and Means Chairman Brady Releases Second Amendment to Tax Bill

Official Document: Additional Amendment from Chairman Brady

Official Documents: Joint Committee on Taxation's Estimated Revenue Effects and Distributional Effects of the Chairman's Amendment

House Ways and Means Committee Approves Tax Bill

Senate Finance Chairman Hatch Comments on the Bill

Official Documents: Description of the Chairman's Mark of the "Tax Cuts and Jobs Act" and Summary

Official Documents: Joint Committee on Taxation's Estimated Revenue Effects and Distribution Effects of the Chairman's Mark

Mayer Brown Analysis: A Good Piece of Music? The Senate Releases Its "Conceptual Mark" for 2018 Tax Reform

Mayer Brown Analysis: US Employment Litigation Round-Up for October 2017

House Ways and Means Chairman Brady Comments on Tax Bill

Official Document: Comments from Chairman Brady

House Republicans Introduce Tax Bill

Official Document: House Tax Bill

Official Document: Joint Committee on Taxation's Description of the House Tax Bill

Official Document: Joint Committee on Taxation's Estimated Revenue Effects of the House Tax Bill

Mayer Brown Analysis: The 2017 Federal Tax Legislation: A First Look

Mayer Brown Analysis: GOP Tax Bill Proposes Changes to the Renewable Energy Industry's Tax Incentives