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House Passes Tax Cuts and Jobs Act: How the Senate Proposal Compares

On November 2, 2017, the House Ways and Means Committee (the “House Committee”) released its plan for comprehensive tax reform: the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “House Bill”). Following a week of hearings,...more

Trump Administration and Congressional Leaders Release Tax Reform Framework

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the “Framework”). The Framework generally...more

One-Year Delay to the Application of Section 385 Documentation Rules

On July 28, 2017, the Treasury Department and the IRS announced in Notice 2017-36 (the “Notice”) that they will delay the documentation rules of Treasury regulation section 1.385-2 to debt instruments issued or deemed to be...more

Update on US Federal Tax Reform Proposals

On April 26, the Trump Administration made its much-anticipated release of several “core principles” of its tax plan. In doing so, the administration affirmed its desire to enact comprehensive corporate and individual tax...more

House Blueprint’s Destination-Based Cash Flow Tax: A Primer

The election of Donald Trump in November has substantially increased the likelihood of major tax reform in the near future. While it is uncertain what shape such reform will take, there has been renewed interest in the...more

Potential US Tax Reform Could Fundamentally Change the Structure of the US Tax System

With the election of Donald Trump, who pledged during the campaign to usher in fundamental tax reform (including major tax cuts), the Republican majorities in Congress have begun planning major tax changes to the Internal...more

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