New Guidance on 163(j) Business Interest Deductions
View Debevoise Update
Key takeaways:
- The IRS issued a notice providing important guidance on the limitation of deductions for net business interest expense under 163(j). Taxpayers can rely on this guidance immediately.
- The IRS will let taxpayers carryforward interest deductions disqualified under old law into post-tax reform tax years, but the deductions will be subject to the new rules.
- C corporations can presume that all of their interest income and expense is business interest and use disallowed interest expense to reduce their earnings and profits.