Proposed Regulations and Guidance on Sections 199A and 163(j) Will Draw on Existing Regulations
The IRS is incorporating relevant existing regulations in drafting the proposed regulations for sections 199A and guidance for section 163(j). However, as noted by Holly Porter, acting IRS associate chief counsel, there are limitations to the degree to which application of these two sections can rely on regulations already existing under other sections due to the differences in nature and purpose of the provisions.