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Tax policy and organizational form : assessing the effects of the Cuts and Jobs Act of 2017 Erin Henry, George A. Plesko and Steven Utke

By: Henry, Erin.
Contributor(s): Plesko, George A | Utke, Steven.
Material type: ArticleArticlePublisher: 2018Subject(s): IMPUESTOS | SOCIEDADES | ORGANIZACION | TIPOS DE GRAVAMEN | SISTEMA FISCAL | REFORMA | ESTADOS UNIDOSOnline resources: Click here to access online In: National Tax Journal v. 71, n. 4, December 2018, p. 635-660Summary: We provide historical context to assess the implications of the Tax Cuts and Jobs Act of 2017 (TCJA) on organizational form. We review the Tax Reform Act of 1986 (TRA86) to assess the extent of organizational form changes in response to changing tax incentives and the effects of those organizational form changes on business operations. We develop a simple analytic model to provide insight into the incentives created by the TCJA and briefly summarize practitioner observations regarding the incentives affecting organizational form decisions. Results suggest that an array of factors make the organizational form decision more difficult and less predictable than in 1986.
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We provide historical context to assess the implications of the Tax Cuts and Jobs Act of 2017 (TCJA) on organizational form. We review the Tax Reform Act of 1986 (TRA86) to assess the extent of organizational form changes in response to changing tax incentives and the effects of those organizational form changes on business operations. We develop a simple analytic model to provide insight into the incentives created by the TCJA and briefly summarize practitioner observations regarding the incentives affecting organizational form decisions. Results suggest that an array of factors make the organizational form decision more difficult and less predictable than in 1986.

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