This title contains authoritative analysis and exclusive practical guidance on a select list of the most important provisions of this massive new legislation, which included the first broad-based corporate rate cut since the Tax Reform Act of 1986. Among the topics covered are replacement of the FSC/ETI rules with the domestic production deduction under new Section 199; a one-year-only tax cut for repatriated foreign dividends under new Section 965; and new rules for expatriated corporations under new Section 7874.

Authors Jasper L. Cummings, Jr., Of Counsel, Alston & Bird LLP, and Robert P. Hanson, Ernst & Young LLP, both noted tax experts and practitioners, guide you through the vast corporate and international changes, including:

• Repeal of the extraterritorial income exclusion
• Deduction for a broad range of domestic production activities
• Interest expense allocation for U.S. multinational parents
• Reduction to two foreign tax credit baskets
• Repeal of personal holding company and foreign investment company rules
• Tax shelter rules
• Disallowance of partnership loss transfers