02 April 2018 IRS issues guidance on computing business interest expense limitation under Section 163(j) The IRS has issued Notice 2018-28, providing guidance for computing the business interest expense limitation under Section 163(j) as amended by the Tax Cuts and Jobs Act, P.L. 115-97. Specifically, the Notice describes regulations that the IRS intends to issue that will clarify that the business interest expense limitation under Section 163(j) applies at the level of the consolidated group. The Notice also indicates that forthcoming regulations will address issues including the treatment of interest disallowed and carried forward under Section 163(j) prior to amendment by the recent legislation, and clarifies that partners and S corporation shareholders cannot apply Section 163(j) to inappropriately "double count" the business interest income of a partnership or S corporation. A detailed Tax Alert is forthcoming. Document ID: 2018-9008 |
