The 2017 tax reform act, commonly known as the Tax Cut and Jobs Act (TCJA), Pub. L. No. 115-97, is the largest tax bill enacted since 1986. The most significant change resulting from the TCJA is the reduction of the corporate tax rate from 35 percent to 21 percent. However, there were a number of additional changes to the tax code resulting from the TCJA including changes impacting individual, corporate, partnership, and S corporate taxpayers.

For each of the three tax provisions noted below, describe the tax provision, the affected taxpayers, note whether the provision existed prior to the TCJA, and the intended impact of the TCJA provision.

• IRC section 199A

• IRC section 951A (global intangible low-taxed income or GILTI tax provision)

• IRC section 59A (base erosion and anti-abuse tax or BEAT)