The Tax Cuts And Jobs Act could be trouble for Dell – and other companies with lots of debt.

The law limits the tax deductibility of interest payments on debt to 30 percent of a company’s EBITDA (earnings before interest, taxes, depreciation, and amortization).

Some say the change unfairly targets capital-intensive industries. Not everyone agrees.

"We want projects to be financed on the basis for what's the best type of financing for the project, not driven by the tax code," said Robert Pozen, senior lecturer at MIT Sloan School of Management.

Dell has an estimated $52 billion in debt.

Experts say the company would have lost $374 million in taxes over the last four quarters under the new tax code.

Dell is looking to restructure its business to get out from under its debt burden.

It could file for an IPO or combine with VMware, its virtualization software subsidiary. Or, Dell could stay as is.

"I think it's very possible that they can live with this limit. They may decide to look down carefully at their cash flow that they have enough cash flow to deduct interest up to 30 percent and that would cover most of their interest," said Pozen.

"They may also say, 'Well at the beginning the interest deductions, we may be a little above 30 percent, but if we look at a five-year projection we think our earnings will be rising and we would be able to pay off a little debt, so that even though we couldn't use the full interest deduction in the first year, we could use it in the second or third year,'" Pozen said.

Dell might also take its Pivotal Software business public, according to Bloomberg.

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