Ezra Dyckman and Charles S. Nelson Treasury Issues Final Regulations Under Section 163(j)
On Nov. 26, 2018, the Treasury Department issued proposed regulations under Section 163(j), and on July 28, 2020, these regulations were finalized. The final regulations largely adopt the proposed regulations, but with some important modifications that are generally favorable to taxpayers.
December 22, 2020 at 11:41 AM
6 minute read
In 2017, P.L. 115-97 was enacted, commonly known as the Tax Cuts and Jobs Act. Among other things, the Act amended Section 163(j) of the Internal Revenue Code to place a limit on deductions for business interest. As amended, Section 163(j) generally limits a taxpayer's deductions for business interest to the sum of (1) the taxpayer's business interest income and (2) 30% of the taxpayer's taxable income (with certain adjustments). Any interest deductions disallowed under Section 163(j) may be carried forward to future years. Section 163(j) applies to all types of taxpayers, including both corporations and partnerships. In the case of a partnership, the rules generally apply at the partnership level.
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