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)…
Thomas May has been advising multinationals on complex US and foreign tax issues for almost 30 years. He has a broad range of experience but has focused his practice primarily on spin-offs, mergers and acquisitions, and the tax-efficient structuring of international operations. Mr. May is recommended in international tax by The Legal 500 and World Tax. He is also consistently named by Legal Media Group's Expert Guides as a leading transfer pricing expert in the United States. His clients have described Mr. May as “extremely talented” and “extremely responsive, insightful.” Most recently, Mr. May has devoted a substantial portion of his time advising clients on the international aspects of the Tax Cuts and Jobs Act of 2017 and the regulations issued thereunder (including challenges to their validity).