Thomas Giegerich, Kristen Hazel, Sandra McGill and Barry Quirke wrote this bylined article on the new federal tax bill’s application to foreign (non-US) multinational entities (FMNEs). Because the bill can increase FMNE tax liability and compliance burdens, the authors urged FMNEs to “thoroughly review their US operations, paying particular attention to cross-border payments to non-US related parties,” adding “it may be the right time to consider restructuring opportunities.”