Date: 2020-09-14
Links to Federal Register: HTML, PDF
(Proposed Regulation: REG-106089-18 HTML, PDF)
Document Number: 2020-16531, RIN: 1545-BO73
Action: Final regulations.
Abstract: This document contains final regulations providing guidance about the limitation on the deduction for business interest expense after amendment of the Internal Revenue Code (Code) by the provisions commonly known as the Tax Cuts and Jobs Act, which was enacted on December 22, 2017, and the Coronavirus Aid, Relief, and Economic Security Act, which was enacted on March 27, 2020. The regulations provide guidance to taxpayers on how to calculate the limitation, what constitutes interest for purposes of the limitation, which taxpayers and trades or businesses are subject to the limitation, and how the limitation applies in consolidated group, partnership, international, and other contexts.
| Notable phrases | Frequency |
|---|---|
| business interest expense | 1468 |
| excepted trade(s) or business(es) | 433 |
| business interest income | 371 |
| section 163(j) limitation | 326 |
| excess business interest expense | 248 |
| non-excepted trade(s) or business(es) | 248 |
| business interest expense carryforward(s) | 222 |
| disallowed business interest expense carryforward(s) | 207 |
| deductible business interest expense | 157 |
| excepted (and|or) non-excepted trade(s) or business(es) | 114 |
| excess taxable income | 106 |
| disqualified interest | 84 |
| electing real property trade(s) or business(es) | 78 |
| floor plan financing interest expense | 76 |
| disallowed disqualified interest | 72 |
| allocable to a trade or business | 61 |
| business interest income deficit | 53 |
| excepted regulated utility trade or business | 51 |
| excess business interest income | 49 |
| members of a consolidated group | 44 |
| negative section 163(j) | 38 |
| 382 disallowed business interest | 26 |
| Reg. Cites | Frequency |
|---|---|
| 1.382-2 | 66 |
| 1.382-6 | 65 |
| 1.163(j)-10 | 58 |
| 1.382-5 | 57 |
| 1.1502-91 | 49 |
| 1.1502-13 | 47 |
| 1.1502-99 | 42 |
| 1.382-7 | 34 |
| 1.163(j)-1(b)(1)(ii)(C) | 33 |
| 1.1502-36 | 33 |
| 1.383-1 | 33 |
| 1.381(c)(20)-1 | 30 |
| 1.1502-79 | 29 |
| 1.1502-21 | 29 |
| 1.383-0 | 29 |
| 1.382-1 | 29 |
| 1.469-9 | 29 |
| 1.263A-15 | 28 |
| 1.882-5 | 28 |
| 1.1504-4 | 28 |
| Sec. Cites | Frequency |
|---|---|
| 163(j) | 1198 |
| 382 | 131 |
| 162 | 53 |
| 704(d) | 47 |
| 469 | 45 |
| 267(b) | 36 |
| 469(c)(7)(C) | 36 |
| 163(j)(3) | 32 |
| 448(c) | 28 |
| 163(d) | 24 |
| 163(j)(1) | 22 |
| 163(j)(7)(B) | 21 |
| 163(j) | 21 |
| 263A | 20 |
| 163(j)(4)(B)(iii)(II) | 19 |
| 168(k) | 18 |
| 704(b) | 18 |
| 163(j)(2) | 17 |
| 461(l) | 17 |
Statistics
Number of pages: 160, words: 170,138, sentences: 6,093
Average words per sentence: 27