New Final Regulations Issued Under Section 163(j) Provide Helpful Clarification
Author: Larry Crouch.; Kristen Garry.; Todd Lowther.; Michael Shulman.; Austin Jones & Adam Sternberg.
Source: Volume 38, Number 03, Spring 2021 , pp.63-74(12)
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Abstract:
This article summarizes the recent final regulations issued under Section 163(j). The regulations provide rules relating to the application of Section 163(j) (enacted as part of the Tax Cuts and Jobs Act of 2017) to partnerships, controlled foreign corporations, and regulated investment companies.Keywords: IRC Sec.163(j), interest expense, adjusted taxable income, T.D. 9943, tentative taxable income
Affiliations:
1: Shearman & Sterling LLP Tax Department; 2: Shearman; 3: Shearman; 4: Shearman; 5: Shearman.