New Final Regulations Revise Rules on the Application of Section 163(j) to CFCs | McDermott Will & Emery
To embed, copy and paste the code into your website or blog: As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest income; (ii) 30% of the taxpayer’s adjusted taxable income (ATI); and (iii) the taxpayer’s floor plan financing interest. On July 28, 2020, the US Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations confirming the application of section 163(j) to controlled foreign co...
Source: jdsupra.com