Marc Gerson, Chair of Miller & Chevalier and former tax counsel for the House Committee on Ways and Means, commented on the speed with which Republicans are aiming to pass and implement tax reform. Many provisions in the bill, which has not yet been signed into law, are slated to take effect on January 1, 2018. "Obviously there is a strong political desire to have the tax reform bill, particularly, the rate reductions, go into effect as soon as possible," Gerson said. "There are practical limitations, however on the ability of taxpayers and the Internal Revenue Service to implement such a comprehensive change to the tax system in such a short time period."

Mr. Gerson's comments were also included in the December 13 Politico article, "GOP Tax Plan Could Bring Big New Year's Surprises."