Treasury Assistant Secretary for Tax Policy David Kautter attended the AICPA National Tax Conference on November 13, 2019, and commented that significant TCJA-related guidance should be expected to be released before the end of 2019.  Such guidance is likely to include proposed regulations addressing (1) federal income tax withholding under section 3402, (2) the executive compensation deduction limitation under section 162(m), and (3) computation of unrelated business taxable income (UBTI) under section 512.  Regulations under section 3402 are needed to address several substantial changes as part of TCJA, including changes to individual income tax rates and suspension of personal exemptions.  TCJA also modified section 162(m) to cover more executive officers and to remove prior exceptions for commission-based and qualified performance-based compensation.  Proposed 162(m) regulations are anticipated to these changes and certain transition rules provided in the new statute.  Finally, proposed guidance under section 512 is expected to address numerous TCJA issues, including a new requirement that UBTI be calculated separately for each unrelated trade or business operated by a tax-exempt organization and the calculation of global intangible low-taxed income (GILTI) for purposes of the unrelated business income tax.  Kautter added that this and additional guidance under numerous other Code sections should be released by year-end or in January 2020.