• Application of new business interest expense limitations in Section 163(j) to a consolidated group, including allocation to departing members
  • Application of new limitations on NOL deductions in Section 172 to a consolidated group
  • New international provisions of the TJCA, including the transition tax, global intangible low-taxed income (“GILTI”)/foreign derived intangible income (”FDII”), and base erosion and anti-abuse tax (“BEAT”)

Speaker