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During 2018, Treasury and the IRS released thousands of pages of proposed regulations and other guidance concerning the 2017 federal tax reform legislation. In addition to tax reform developments, taxpayers also need to consider the impact of the Section 385 regulations, where the only change to date was to remove the documentation rules while not removing or modifying the remaining portions of the 385 regulations.

The release of a significant volume of proposed guidance in a relatively short period of time creates challenges for businesses and state tax practitioners regarding the impact of the new guidance on state tax matters. 

This PwC Tax Insight highlights some of the major considerations in evaluating the impact of certain federal provisions and notes the need for separate state calculations for many federal tax reform matters.