Treasury to Release TCJA Guidance

The Treasury Department announced that it expects to release numerous proposed and new regulations by year end or in January 2020, implementing the Tax Cuts and Jobs Act (TCJA). According to Treasury Assistant Secretary for Tax Policy David Kautter, as reported in Tax Notes, 60% of the TCJA’s provisions have been completely implemented, with another 10% to be completed within the next six weeks.

Areas on which guidance is expected to be issued include:

• Proposed carried interest regs under Internal Revenue Code Section 1061. 
• Proposed regs for dealing with the cap on the state and local tax deduction under IRC Section 164.
• Final regs regarding the increased basic exclusion amount for estate and gift taxes under Section 2010.
• Final regs on qualified opportunity zones.
• Proposed regs on the interest expense deduction limitation under Section 163(j).
• Proposed regs on Section 3402 withholding.
• proposed regs under Section 512 on computing unrelated business taxable income for exempt organizations’ separate trades or businesses.
• Proposed regs on source rules relating to foreign income.
• Proposed regs regarding itemized deductions for individuals and corporations, specifically addressing the executive compensation deduction limitation under Section 162.