By Todd Reinstein and Annette Ahlers (August 21, 2018, 3:13 PM EDT) -- Although Section 382 of the Internal Revenue Code generally was left unchanged by the Tax Cuts and Jobs Act,[1] issues have arisen regarding its application to a new provision that modifies the first-year treatment of certain deductions related to qualified property under the rules. Specifically, questions have arisen about how the new 100 percent expensing rules impact the calculation of built-in gains and losses under Section 382. The IRS is beginning to address these issues in guidance and to consider questions related to the new Section 163(j) interest limitation rules and their potential application under Section 382 when there is an excess interest carryforward after an "ownership change" as defined in Section 382(g)....