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Michael Tedesco

Michael Tedesco is an associate in Baker McKenzie's Tax Practice Group in New York.

In brief The Tax Cuts and Jobs Act of 2017 (Public Law 115-97) (TCJA) made significant changes to Section 163(j) effective for tax years beginning after December 31, 2017. On December 28, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (“Proposed Regulations”)┬áimplementing the amendments to Section 163(j)…