Editor: Mo Bell-Jacobs, J.D. The law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97, has received significant media attention over the past year. However, one component of the law that has remained largely under the radar is the TCJA's liberalizing of the S corporation rules, particularly with respect to non-U.S. ownership. The TCJA revised the long-standing prohibition on a nonresident alien's being a potential current beneficiary of an electing small business trust (ESBT).