NYAIR Episode 23
U.S. Tax Reform: Opportunities & Challenges
Dive into the most sweeping changes in US tax law in three decades and what they mean for dealmakers, fund managers, and global investors. In this NY-AIR episode, industry leader David Sites (National Managing Principal, Grant Thornton) unpacks practical strategies, regulatory uncertainty, and how to structure deals for optimal results under the Tax Cuts and Jobs Act and subsequent regulatory shifts.
Featured Guests
David Sites
National Managing Principal, Washington National Tax Office | International Tax Solutions, Grant Thornton
A recognized authority on US and international tax, David Sites leads Grant Thornton’s International Tax practice and Washington National Tax Office. With nearly 25 years of cross-border planning, M&A structuring, and US tax policy experience, he advises asset managers, PE firms, and multinationals on global structuring, ASC 740, and foreign asset strategy. David is a frequent speaker, AICPA panel chair, and advisor for Fortune 100s as well as leading funds.
Key Insights From This Episode
Forget What You Knew: Complete Tax Overhaul
The Tax Cuts and Jobs Act (TCJA) marks a “clean slate,” requiring fund managers to re-think all conventional tax structuring and compliance models.
Corporate Tax Rate, Expensing, and Leverage
The shift to a 21% corporate rate and 100% immediate expensing on new property flips M&A and deal structuring logic—driving a premium for asset deals and changing capital allocation decisions for private equity and corporates.
Investment Structuring: Partnerships vs. Corporates
The new regime blurs historic advantages of flow-through versus C-corp entities, especially for reinvestment strategies, and raises new questions around the timing/distribution of carry and investment exit.
The International “GILTI” Stick—and the Export Carrot
Quasi-territoriality, the “GILTI” minimum tax, and the FDII export incentive radically complicate multinational tax exposure, effective rates, and future investment of foreign earnings—especially for IP- and export-heavy businesses.
NOL, Deduction, and Interest Limitations
New rules for net operating losses, deduction caps, and limits to interest deductibility have far-reaching impacts on leveraged structures, recap strategies, and fund models—requiring close modeling and scenario analysis for capital stack planning.
Guidance Risk and Regulatory Uncertainty
The breathtaking speed of the tax overhaul leaves practitioners “drinking from a firehose,” with evolving guidance, regulatory ambiguity, and political risks creating major risk/opportunity for decision-makers in 2018–2020 and beyond.
Access the Full Conversation
Get the full episode and a customizable insights deck. Every asset manager, CFO, and fund tax lead will find critical frameworks to navigate the new US tax landscape and seize global opportunities.
Soundbites Worth Saving
“Forget everything you knew about US tax; start with a clean slate—and model each deal from scratch.”
— David Sites
“21% corporate rate plus 100% expensing will favor asset deals and change returns for capital-intense businesses.”
— David Sites
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