Читать книгу International Taxation - Adnan Islam - Страница 19

The TCJA provisions affect tax years beginning in 2018, with some exceptions.

 A permanent 21% corporate income tax rate effective in 2018, representing a 40% decrease over the prior corporate income tax rate of 35%

 Limitations on business and personal net operating losses and business interest deductions

 Repeal of the corporate alternative minimum tax (AMT)

 Repeal of the domestic production activities deduction (DPAD)

 New broader interest expense limitation regulations under Section 163(j) that limit interest expense to 30% of Adjusted Taxable Income (ATI)

 A 20% deduction for qualifying pass-through income from partnerships, LLCs, and S corporations; notable exceptions (SSTBs) that do not qualify are in consulting, accounting, law, healthcare and medicine, and related fields — The “pass-through deduction” for up to 20% of Qualified Business Income of U.S. pass-through business entities under Section 199A (generally requires W-2 employee expense) that require modeling between the effective tax rate of a pass-through entity versus a C corp entity.

 Revisiting the technical rules surrounding the Accumulated Earnings Tax (Sections 531, 532) and Personal Holding Company Tax (Sections 541-543) for C corporations