US tax reform: practical aspects

US tax reform has introduced fundamental changes, including new concepts like BEAT and GILTI, tightened interest deductibility and hybrid rules. BEAT is truly novel and all companies with significant US operations should consider its effect. Its minimum tax concept is likely to be most concerning for multinational companies providing services. Meanwhile, the stricter interest deductibility rules bring the US into line with BEPS Action 4. Relatively limited hybrid rules have also been introduced. UK professionals advising businesses with large US operations should devote time to understanding the rules and work with affected businesses to analyse their impact.