1 Introduction
The United States is currently in the middle of the most
hyper-partisan political atmosphere in generations.
Bipartisan solutions to problems have become nearly impossible, as
each side refuses to agree to a solution that might place the other
side in a positive light. Against that background, Congress
enacted a comprehensive tax reform package less than two weeks
before the end of 2017. This tax reform legislation has
become the single biggest item of focus in the U.S. tax
practitioner world.
Public Law No. 115-97 (the "Act") was signed into law
by President Donald Trump on December 22, 2017. The Act was
signed just 51 days after it was introduced by the House of
Representatives on November 2, 2017. Unsurprisingly, the Act
is entirely partisan, having received support only from Republican
members of Congress. As a measure of just how partisan the
Act is, the Act, which was originally named the "Tax Cuts and
Jobs Act" (and still is popularly
