Tax Cuts and Jobs Act, Internal Revenue Code (IRC), Taxable Income

The "One Big Beautiful Bill" Key Tax Takeaways

Baker Botts L.L.P. on 7/9/2025

On July 4, 2025, the legislation commonly known as “The One Big Beautiful Bill Act” (the “BBBA”) was enacted. The BBBA makes permanent, extends and, in certain cases, modifies, a number of provisions from the 2017 Tax Cuts...more

Taxing A Foreigner’s Sale of a Partnership Interest – Déjà Vu All Over Again

Rivkin Radler LLP on 8/12/2024

There is no denying that many parts of the Code are complex and, in some cases, too obscure for many “laypersons” to comprehend. Over time, this reality spawned the need for advisers who are both knowledgeable and experienced...more

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Eversheds Sutherland (US) LLP on 5/27/2021

Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: ..Allows controlled...more

New Final Regulations Revise Rules on the Application of Section 163(j) to CFCs

McDermott Will & Schulte on 1/27/2021

As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more

New Proposed Regulations Would Revise the Application of Section 163(j) to CFCs

McDermott Will & Schulte on 8/13/2020

As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more

The newest addition to your summer reading list: Section 163(j) regulations arrive just in time for the dog days of summer

Eversheds Sutherland (US) LLP on 8/11/2020

On July 28, 2020, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) issued final and newly-proposed regulations under section 163(j) that taxpayers and practitioners alike were eagerly awaiting....more

IRS Proposes Section 163(j) Regulations – New Business Interest Expenses Deduction Limit

McDermott Will & Schulte on 12/21/2018

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

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

Foster Garvey PC on 2/7/2018

“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

Tax Cuts and Jobs Act › Internal Revenue Code (IRC) › Taxable Income

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