The Internal Revenue Service and the Treasury Department recently issued proposed regulations addressing the limitation on deductions for business interest expense under Section 163(j) of the Internal Revenue Code. As discussed in more detail in this memorandum, the Proposed Regulations provide critical guidance regarding many of the technical provisions in Section 163(j) as well as the application of Section 163(j) to different types of entities, including partnerships, controlled foreign corporations and corporate members of a tax consolidated group.