Surgent's Section 163(j): Business Interest Limitation After TCJA (S163)

Description

The Tax Cuts and Jobs Act added Section 163(j), limiting the deduction of business interest for certain taxpayers. Section 163(j) is accompanied by hundreds of pages of IRS regulations addressing important elements of this statute, which we have incorporated into digestible parts of this program. Many taxpayers will be exempt from Section 163(j), and others can elect not to be subject to its provisions. The program covers the impact of the new legislation as well as which taxpayers are not subject to its provisions, either automatically or electively. The program will be updated when the IRS issues final regulations.

Highlights

• Which taxpayers are subject to Section 163(j)?
• The $26 million gross receipts test
• What is an excepted trade or business?
• Tax shelters and electing real property businesses
• What is business interest for Section 163(j) purposes?
• How does Section 163(j) impact pass-through entities?
• Latest regulations

Objectives

• Understand how Section 163(j) impacts taxpayers, including pass-through entities
• Calculate the $26 million gross receipts test

Designed For

Tax practitioners who anticipate advising clients regarding this complex provision