On November 26, 2018, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pursuant to section 163(j). Public Law 115-97, the Tax Cuts and Jobs Act (TCJA), amended Internal Revenue Code (Code)...more
The newly enacted version of section 163(j) limits deductions for business interest expense. Although the prior version of section 163(j) applied almost exclusively to US corporations with non-US parents, the new version of...more