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United States - Introduction to the US Tax Reform Act

United States
P. Carman
Derivatives & Financial Instruments, 2018 (Volume 20), No 5
3 September 2018
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.
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