IRS Releases Guidance on Section 163(j)
Posted on Apr 4, 2018 in Individual Taxation, News
On April 2, 2018, the IRS issued Notice 2018-28, which provides guidance related to the interest deductibility limitation in Section 163(j). The Notice clarifies that Section 163(j) will treat taxpayers who file a consolidated return as a single taxpayer and that interest disallowed under the prior version of Section 163(j) may be carried forward and treated as business interest in taxable years beginning after December 31, 2017. Notably, the Notice did not address the applicability of Section 163(j) to controlled foreign corporations or to consolidated groups where one of the members of the group is exempt from the Section 163(j) limitation.
Read more here: Notice 2018-28