The introduction of the Tax Cuts and Jobs Act of 2017 (Tax Act) significantly overhauled the U.S. tax code and, in turn, the tax assumptions and practices relied upon by the PE industry. As the dust has settled in the intervening years, tax experts have resolved some of the outstanding issues raised by the Tax Act. They have also, however, unearthed significant loopholes and defects that require future legislative attention. The current state of the Tax Act and its impact on the PE industry were explored in a recent Practising Law Institute panel featuring Jonathan A. Goldstein, partner at Simpson Thacher, and Sara B. Zablotney, partner at Kirkland & Ellis. This second article in a two-part series explores the deduction for pass-through business income; the Tax Act’s anti-hybrid and base erosion rules; taxation of cross-border investments; and the tax impetus for converting public PE partnerships to corporations. The first article described changes introduced by the Tax Act to the taxation of carried interest, withholding on transfers of partnership interests by non-U.S. persons and the limitation on the deduction of business interest. See “New Tax Law Carries Implications for Private Funds” (Feb. 1, 2018).