The enactment of H.R. 1, formerly known as the Tax Cuts and Jobs
Act ("TCJA"), on December 22, 2017 marks the first major
overhaul of the U.S. federal income tax system in over 30 years.
The new law makes sweeping changes to the tax code with widespread
business implications that create challenges and opportunities for
corporate leaders as they address a variety of operational
decisions.
In particular, the new law has reshaped the way corporations
look to optimize their international operations and intangible
property holding structures, giving rise to potential planning
opportunities and particularly with surrounding acquisitions. As
multinational companies integrate acquired IP, they may elect to
transfer the economic ownership of certain acquired intangibles
within the controlled group for a host of reasons, including supply
chain optimization, improved tax efficiency, the simplification of
intercompany transactions, and the facilitation of research
