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US tax reform: recent changes and next steps

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US tax reform at the end of 2017 resulted in fundamental change. However, the reform did not stop there: since then, pages of proposed regulations have been issued (and in many cases finalised) and further proposed regulations have been released, along with some additional tax policy decisions where bipartisan agreement could be achieved. Key changes include proposed BEAT regulations, which set out procedures under which a taxpayer may elect to ‘disavow’ tax deductions; and extensive foreign tax credit regulations, which clarify the impact of and provide updates to previously proposed regulations, as well as introducing new proposed regulations. Further change is expected, regardless of who wins the US elections in November. UK practitioners would therefore be well advised to continue to consider future rule changes, in order to be best placed to advise groups with a US presence.
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