Treasury and IRS Release Final Regulations under Section 163(j) with respect to Partnerships and CFCs
Posted on Jan 5, 2021 in International Tax
On January 5th, the Department of the Treasury and the Internal Revenue Service released final regulations under section 163(j). Amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) generally limits a taxpayer’s interest deduction to the sum of its business interest income, floor plan financing interest, and 30% of its adjusted taxable income (ATI). The regulations finalize...
OMB Completes Its Review of Proposed Regulations under Section 163(j)
Posted on Jan 5, 2021 in International Tax
The Office of Management and Budget (OMB) has completed its review of proposed regulations under section 163(j). Section 163(j) generally limits a taxpayer’s interest deduction to the sum of its business interest income, floor plan financing interest, and 30% of its adjusted taxable income. The proposed regulations provide rules applicable to partnerships and controlled foreign...
Treasury and IRS Release Final and Proposed Regulations under Section 163(j)
Posted on Jul 28, 2020 in Uncategorized
On July 28, the Department of the Treasury and the Internal Revenue Service released final and proposed regulations under section 163(j). Amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) generally limits a taxpayer’s interest deduction to the sum of its business interest income, floor plan financing interest, and 30% of its adjusted taxable income. The provision was further...
OMB Begins Review of Proposed and Final Regulations Under Section 163(j)
Posted on Jun 17, 2020 in Uncategorized
On June 15, Treasury submitted final and proposed regulations to the Office of Management and Budget (OMB) for review. The IRS had indicated that the modifications to the regulations since OMB’s last review of the package reflect changes made to section 163(j) under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Among other provisions, the CARES Act amended section...
IRS Issues Guidance on CARES Act changes to Section 163(j)
Posted on Apr 15, 2020 in Uncategorized
The IRS has issued Rev. Proc. 2020-22 to provide guidance to taxpayers applying the provisions of section 163(j), as amended by the CARES Act. Among other provisions, the CARES Act amended section 163(j) to allow taxpayers to deduct up to 50% of their adjusted taxable income (up from 30%), plus interest income and floor plan financing income, for taxable years beginning in either 2019...
CARES Act Amends TCJA Provisions
Posted on Mar 30, 2020 in Uncategorized
On March 27, Congress passed the Coronavirus Aid, Relief, and Economic Security (CARES) Act. While the Act is primarily focused on the coronavirus epidemic, the Act made a few significant changes to provisions enacted by the Tax Cuts and Jobs Act (TCJA). The Act: • Allows net operating losses (NOLs) arising in 2018, 2019, or 2020 to be carried back five years and exempts NOLs from the...
OMB Completes its Review of Proposed Regulations under Section 163(j)
Posted on Mar 24, 2020 in Uncategorized
The Office of Management and Budget (OMB) has completed its review of proposed regulations under section 163(j). Section 163(j) generally limits a taxpayer’s interest deduction to the sum of its business interest income, floor plan financing interest, and 30% of its adjusted taxable income. The IRS had previously stated that the proposed section 163(j) regulations would likely be...
Treasury Intends to Finalize All Major TCJA Guidance by October 1
Posted on Feb 21, 2020 in International Tax
Speaking at a conference yesterday, Chip Harter, Treasury deputy assistant secretary for international tax affairs, stated that he is “fairly confident” that Treasury will be able to finalize all major guidance related to the Tax Cuts and Jobs Act by October 1st of this year. With respect to timing, Harter stated that he expects that regulations under section 901(m) will be released...
OIRA Completes Its Review of Final 163(j) Regulations
Posted on Feb 5, 2020 in Uncategorized
On January 31, the Office of Management and Budget (OMB) completed its review of final regulations under section 163(j). Section 163(j) generally limits a taxpayer’s interest deduction to the sum of its business interest income, floor plan financing interest, and 30% of its adjusted taxable income. The IRS had previously stated that the final regulations would likely be released along...
Discussion Draft of the “Tax Technical and Clerical Corrections Act” Released
Posted on Jan 3, 2019 in International Tax
Rep. Kevin Brady, former Chairman of the House Ways and Means Committee, issued a draft of technical changes to the Tax Cuts and Jobs Act (TCJA) on January 2, 2019, just prior to relinquishing the Chair to Rep. Richard Neal. The dozens of proposed changes, written to implement Congressional intent and correct provisions in the TCJA, include restoration of the applicable recovery...
OIRA Receives Proposed Section 163(j) Regulations for Review
Posted on Oct 26, 2018 in Individual Taxation, International Tax, News, Pass-through Taxation, Tax Accounting
The Office of Information and Regulatory Affairs (OIRA) received draft proposed regulations under section 163(j), addressing the limitation on business interest deductions, on October 25, according to the Office of Management and Budget’s website. As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) generally limits business interest expense deductions to the sum of business...
Treasury Confirms Issuance of Transition Tax Regulations by the End of the Year
Posted on Oct 11, 2018 in International Tax
Brenda Zendt, special adviser to the Treasury Office of International Tax Counsel, corroborated a prior report that the Treasury Department intends to issue final Section 965 regulations by the end of 2018. Treasury deputy assistant secretary for international tax affairs, Chip Harter, previously commented on the deadline while discussing Treasury’s goal to issue proposed regulations,...
IRS Provides Timeline for Tax Reform Guidance
Posted on May 15, 2018 in International Tax, News
During the ABA Section of Taxation meeting in Washington, D.C. on May 12, David Kautter, the acting IRS commissioner, provided a rough timeline as to when IRS intends to release guidance related to the 2017 tax act. Kautter stated that a notice regarding section 965 (the so-called transition tax) may be released in the next two weeks and that proposed regulations are slated for release...
Eversheds Sutherland Releases Videocast Providing a Basic Overview of International Tax Provisions
Posted on Feb 7, 2018 in International Tax, News
Eversheds Sutherland (US) LLP recently released a videocast which provides a brief overview of the impact of international tax provisions. This short video provides a concise overview of various international provisions in the recent legislation formerly known as the Tax Cuts and Jobs Act, including those related to the reduced corporate tax rate, the shift to a hybrid...
Regulations and Notices to Provide Guidance on New Tax Bill
Posted on Feb 5, 2018 in International Tax, News
As the early guidance period for the new tax bill continues, the Treasury and IRS plan to shift to focusing on developing regulations over the next six months. A less notice-oriented approach is expected, with only five to ten limited-scope notices addressing basic questions, such as section 163(j) business interest issues, anticipated. IRS and Treasury tax reform projects will be...