Tax Reform Insights: IRS Proposes Section 163(j) Regulations – New Business Interest Expenses Deduction Limit - McDermott Will & Emery

Tax Reform Insights: IRS Proposes Section 163(j) Regulations – New Business Interest Expenses Deduction Limit

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Overview


Kevin Hall, Emily Mussio, Justin Jesse and David Sherwood authored this bylined article about the proposed regulations made by the Internal Revenue Service to limit the amount of business interest a taxpayer may deduct. “With the amendment of Code Section 163(j), the ability of some taxpayers to deduct interest on intercompany debt has been diminished substantially,” they wrote. “This may require a taxpayer to reevaluate funding and capital structures, and may necessitate a new strategy.”