Leading the way?

Craig Hillier and Adam Becker provide an overview of recent developments in US tax reform

The most significant US federal tax reform since 1986, commonly referred to as the ‘Tax Cuts and Jobs Act’ (TCJA), turned 18 months on 22 June this year. That 18-month milestone has special significance for US federal rule-making procedures as a safe harbour by when a regulation can be issued and applied retroactively to the date of enactment of the statute to which the regulation relates (see Section 7805(b)(2). Regulations issued after 18 months may still have retroactive effect, subject to meeting more nuanced requirements under Section 7805(b)(1)).