IRS Issues Proposed Regulations on Section 163(j) Interest Deduction Limitation: Proposed Regulations Would Implement and Provide Guidance Regarding the New Section 163(j) Provisions

Sullivan & Cromwell LLP - December 31, 2018

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.