The Tax Cuts and Jobs Act, signed into law on December 22, 2017, represents the biggest change to U.S. tax law since adoption of the 1986 Code. In addition to rate cuts and various individual and corporate reforms, the Act introduces several major changes to existing U.S. international tax laws. While the reform effort is intended to make U.S. companies more competitive while guarding the U.S. tax base, the rushed legislative process and complexity of the international provisions have already spurred a number of technical and interpretive questions. But for now, savvy (and flexible) taxpayers may have opportunities to optimize their situation in the new landscape while we await further guidance from the IRS and Treasury.