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

Recorded on: Apr. 23, 2018
Running Time: 01:10:18

Full Transcript:



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To access the streaming media of this presentation, please purchase the corresponding seminar segment.

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam.

Upon the successful completion of this program, the participant will be able to:
  • Recall the provisions of new Internal Revenue Code (IRC) §163(j) and how they differ from those of old §163(j).
  • Recognize the impact of new Internal Revenue Code (IRC) §163(j) on partnerships and the issues associated with its application thereto.
  • Identify the impact of new Internal Revenue Code (IRC) §163(j) on cross-border transactions.

Course Overview:
This program will focus on:

  • The provisions of new Internal Revenue Code (IRC) §163(j) and how they differ from those of old §163(j).
    • Overview.
  • The impact of new Internal Revenue Code (IRC) §163(j) on partnerships and the issues associated with its application thereto.
    • Treatment of partnership interest income.
    • Rules for carryforward of excess business interest.
    • Treatment of excluded businesses conducted by a partnership.
  • The impact of new Internal Revenue Code (IRC) §163(j) on cross-border transactions. 
    • Subpart F income.
    • Tested income.

CPE Program Level: Update

Intended Audience: CPA’s, tax accountants, tax lawyers, taxpayers, and others seeking the latest information on the implications of the Tax Cuts and Jobs Act (TCJA) with respect to new IRC §163(j)’s limitation on the deductibility of business interest and its impact on transaction planning.

Prerequisites: A general understanding of new IRC §163(j)’s limitation on the deductibility of business interest imposed pursuant to the latest provisions of the Internal Revenue Code (IRC).

Advanced Preparation: None

Instructional Method: QAS Self-Study

Updated: May 2018

Credit Information: 1 CPE credit is available upon completion of this program’s 3 content-review questions and a minimum passing score of 70% on the 5-question final exam.

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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