Recently proposed regulations (REG-106089-18) provide needed guidance to the broadly applicable limitation on business interest expense under IRC § 163(j).
This Bottom Line videocast includes key elements of the proposed regulations, such as:
adoption of a broad definition of "interest"
treatment of historic carryforwards and coordination rules
clarification of the application of section 163(j) to consolidated groups, pass-through entities, non-US entities, and excepted trades or businesses
Legal Alert: INXS? IRS issues proposed regulations under section 163(j)
Legal Alert: Proposed 163(j) regulations provide needed guidance to utilitiesDiscover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.