John Warner, shareholder in the firm's Tax section, comments on the pending finalization of the Tax Cuts and Jobs Act and what the updated regulations can mean for businesses and taxpayers. John's comments include:
“Multinationals are holding some of their restructuring in advance, because the devil’s in the details,” said John Warner of Buchanan Ingersoll & Rooney PC in Washington, D.C. “There will be an acceleration of planning once the regulations are finalized.”
“The rules are more principle-based than practically based,” Warner said. “There are some components, advertising and promotion, that is explicitly not cost of goods sold. But there’s a lot of discretion in other expenses, that are kind of, sort of associated with the purchase of goods that you’re reselling.”
“The stuff that was passed last year turns a lot of the incentives for taxpayers on their head,” Warner said. “If you’re the tax administrator you have to worry that all of your anti-avoidance and similar rules were geared to preventing abuse in the old world. Now, as you think through what the new world is like, some of the incentives are going to be different.”
Read Law360's article "In 2019, Global Tax Rules in TCJA to Take Flight."