transcript   Transcript

Business Interest Deductions under New Section 163(j): Interpretive Issues and Impact on Transaction Planning

Recorded on: Apr. 23, 2018
Running Time: 01:10:19

Full Transcript:

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Taken from the Web Program Tax Cuts and Jobs Act Update 2018: Issues for U.S. Businesses and Individuals Recorded April, 2018 in New York

Business Interest Deductions under New Section 163(j): Interpretive Issues and Impact on Transaction Planning [01:10:18]
• Allocation of interest expense and other items among a taxpayer's excluded and non-excluded businesses
• Coordination with other limits on interest deductions
• Application to consolidated groups
• Interaction with Section 382 and COD rules
• Partnership issues: treatment of partnership interest income; rules for carryforward of excess business interest; treatment of excluded businesses conducted by a partnership
• Impact on cross-border transactions
John J. Lutz, Dana L. Trier, Philip Wagman

Presentation Material

  • New Section 163(j): Interpretative Issues and Impact on Transaction Planning
    John J. Lutz, Dana L. Trier, Philip Wagman
  • New York State Bar Association Tax Section: Report on Section 163(j) (Report No. 1393) (Handout)
    Philip Wagman
  • IRS Notice 2018-28: Initial Guidance Under Section 163(j) as Applicable to Taxable Years Beginning After December 31, 2017 (Handout)
    Philip Wagman
    • (s)
      John J Lutz ~ McDermott Will & Emery LLP
      Dana L Trier ~ Davis Polk & Wardwell LLP
      Philip Wagman ~ Clifford Chance US LLP
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