Law360 (January 1, 2019, 12:03 PM EST) -- With the headline-grabbing issues out of the way, practitioners expect the Treasury in early 2019 to address loose ends of the largest overhaul to the U.S. tax code’s international framework in a half-century, before it is fully implemented and operational.
Companies that have kept their powder dry and waited over the past year will likely begin to act, creating new international structures around the Tax Cuts and Jobs Act’s rules and accelerating the repatriation of overseas income. After years of speculation, experts will finally have some evidence about whether the TCJA’s complex international system of levers, roadblocks, carrots and sticks will achieve...
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