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.