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Tatyana Johnson

Tatyana Johnson is a national partner in Baker McKenzie’s Tax Practice Group in the New York office, where she works on international tax planning and transactions. She is an active participant at both in-house and external seminars and conferences and has served as an adjunct professor in the Tax Planning & Transactions course at Fordham University School of Law.

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”) implementing the amendments to Section 163(j)…