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Tax Reform – A Few Provisions In Track Changes

Annette Nellen Tax Reform Changes

I often find it helpful to see how tax legislation changes existing Internal Revenue Code sections. So, I took a few and made the modifications called for in P.L. 115-97 (12/22/17) (the Tax Cuts and Jobs Act), and show how they change the relevant Code section using track changes.  I also include the effective date information.  For the changes to 448, I also include a caution about how the favorable methods changes don’t apply to “tax shelters” which could include some limited partnerships and LLCs even though they don’t act like a typical tax shelter.

Here are the ones I modified:

Section 1 – tax rates including kiddie tax change

Section 62 – changes to AGI

Section 163 – changes to mortgage interest and the new interest limitation for non-small entities (and tax shelters – see comment above)

Section 164 – changes to limit the Schedule A deduction for state and local taxes for 2018 through 2025. This track changes includes the text of the 1944 Cumulative Bulletin reference that is at footnote 168 of the PL 115-97 committee report (click Section 164 for all of this). And, thanks to attorney Libin Zhang for finding and improving a copy of these 1944 CB pages you can find here.

Section 274 – changes to entertainment, meals, travel and awards

Section 448 – changes to broaden availability of the cash method of accounting as well as similar changes to unicap (263A), inventory (471) and certain construction contracts (460(e))

Section 451 – changes to timing of income for accrual method taxpayers

Section 1031 – restricts like-kind exchanges to non-dealer real property

Hope you find this useful.  Note, these are just a few of the many changes in P.L. 115-97!

Also see historical links here.

What do you think? Annette Nellen.



Annette Nellen, CPA, Esq., is a professor in and director of San Jose State University’s graduate tax program (MST), teaching courses in tax research, accounting methods, property transactions, state taxation, employment tax, ethics, tax policy, tax reform, and high technology tax issues.

Annette is the immediate past chair of the AICPA Individual Taxation Technical Resource Panel and a current member of the Executive Committee of the Tax Section of the California Bar. Annette is a regular contributor to the AICPA Tax Insider and Corporate Taxation Insider e-newsletters. She is the author of BNA Portfolio #533, Amortization of Intangibles.

Annette has testified before the House Ways & Means Committee, Senate Finance Committee, California Assembly Revenue & Taxation Committee, and tax reform commissions and committees on various aspects of federal and state tax reform.

Prior to joining SJSU, Annette was with Ernst & Young and the IRS.

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One thought on “Tax Reform – A Few Provisions In Track Changes

  1. Avatar Ann Collins says:

    Thanks for doing the heavy lifting – excellent.

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