By Stanley Barsky, Michael Bookbinder and Eric Michaels (January 24, 2018, 12:23 PM EST) -- The Tax Cuts and Jobs Act, enacted on Dec. 22, 2017, contains several provisions that significantly affect the federal income tax consequences of structures often used in domestic mergers and acquisitions. These are the pass-through provisions of Section 199A, provisions relating to treatment of carried interests, changes related to treatment of certain intellectual property, and imposition of tax (and withholding obligations) in connection with a foreign person's sale of interests in a partnership that has effectively connected income.[1] The act contains a number of ambiguities, which makes application uncertain, and we expect and hope for clarifying regulations to be issued and technical corrections to be enacted. Until then, taxpayers and their advisers must tread carefully, relying on legislative history and, in certain cases, pre-act authorities to determine the scope and application of these provisions....