188bet亚洲真人体育下载 Comments on Initial Guidance for Deduction of Business Interest

的 美国注册188bet亚洲真人体育下载 (188bet亚洲真人体育下载) 建议 到美国.S. Department of the Treasury and Internal Revenue Service (IRS) in a July 9 letter about the initial guidance governing the deduction of business interest expense by certain large businesses, as amended by the 税 Cuts and Jobs Act (TCJA).

在2018-28年通知中， Initial Guidance Under Section 163(j) as Applicable to 税able Years Beginning After December 31, 2017, Treasury and IRS described the rules they expect to issue and requested comments about the additional guidance that taxpayers will need to compute the business interest expense limitation under Internal Revenue Code (IRC) section 163(j).

的 188bet亚洲真人体育下载 made more than 20 建议, a number with illustrative examples, in the following areas related to section 163(j):

• Treatment of Disallowed Disqualified Interest from Last 税able Year Beginning Before January 1, 2018:
  • Rules for the allocation of business interest from a group treated as affiliated under the super-affiliation rules applicable to old section 163(j) to taxpayers under new section 163(j)

• C Corporation Business Interest Expense and Income:
  • Treatment of interest expense and income as business interest
  • Treatment of a partnership’s investment interest expense with respect to its corporate partners

• Application of Section 163(j) to Consolidated Groups:
  • Allocation of the limitation among group members
  • Treatment of disallowed interest deduction carryforwards when a member leaves the group
  • Treatment of disallowed interest deduction carryforwards of a member that joins the group, including whether the carryforwards are subject to a separate return limitation year 
  • 税收的申请. 注册. § 1.1502-32 to disallowed interest deductions
  • Application of section 163(j) to a consolidated group with one or more members that conduct a trade or business described in section 163(j)(7)(A)(ii), (3), 或(iv), 经TCJA修订, or whose members hold an interest in a non-corporate entity such as a partnership that conducts such a trade or business

• Impact of Section 163(j) on Earnings and Profits

• Other – 的 Application of the Section 163(j) Limitation on Partnerships:
  • Treatment of excess business interest carryforwards by partners
  • Impact of section 743(b) adjustments
  • Real property trade or business election
  • Application of section 704(c) methods
  • Allocation of items between exempt and non-exempt businesses

的 188bet亚洲真人体育下载 said it intends to submit a second comment letter on the interaction of IRC section 163(j) with international tax provisions.