Introduction to the US Tax Reform Act

Journal
United States
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2018 (Volume 20), No. 5
This article deals with several changes on US taxation of financial instruments under the US TCJA. The changes include the introduction of a new interest barrier, a limitation on the deductibility of payments on hybrid instruments or in hybrid transactions, an excise tax on base erosion payments, a new system of allowing a deduction for distributions from non-US subsidiaries and changes in the US controlled foreign corporation rules.