EYUS final and proposed regulations under Section 163(j) narrow definition of business interest expense, expand anti-avoidance rules and substantially revise rules for foreign corporations
|Tax Alerts, National/Federal Taxation, L ...|United States
On 28 July 2020, the United States (US) Treasury Department released final regulations (TD 9905) with guidance on applying the limitations on the deductibility of business interest expense (BIE) under Internal Revenue Code1 Section 163(j) (the Final Regulations), which was significantly modified by the Tax Cuts and Jobs Act (TCJA) and then temporarily modified by the Coronavirus Aid, Relief, …
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