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    IRC Section 163 (j) limits the deduction for BIE for tax years beginning after December 31, 2017, to the sum of (1) the taxpayer's BII, (2) 30% of the taxpayer's ATI, and (3) the taxpayer's floor plan financing interest. BIE is interest that is paid or accrued on indebtedness that is properly allocable to a trade or business.
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    IRC Section 163 (j) limits the deduction for BIE for tax years beginning after December 31, 2017, to the sum of (1) the taxpayer's BII, (2) 30% of the taxpayer's ATI, and (3) the taxpayer's floor plan financing interest. BIE is interest that is paid or accrued on indebtedness that is properly allocable to a trade or business.
    taxnews.ey.com/news/2021-0059
    The new 163 (j) now limits a taxpayer’s deduction for business interest expense to the sum of: business interest income, 30% of the newly calculated ATI of the taxpayer, and floor plan financing interest (which only applies to dealers of certain self-propelled vehicles and machinery).
    www.bonadio.com/news-events/articles/the-new-int…
    The TCJA significantly expanded IRC §163 (j) by limiting the IRC §163 deduction for net business interest expense to 30% of any taxpayer’s adjusted taxable income (ATI), with an exemption for small businesses and an option for real estate and farming businesses to elect out of the limitation.
    pro.bloombergtax.com/brief/business-interest-expe…
     
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    What is IRC Section 163(J)?The Tax Cuts and Jobs Act amended IRC Section 163 (j) to limit the deduction for net business interest expense in excess of interest income. The limitation is based on a percentage (30% for most years) of adjusted taxable income (ATI) computed under Section 163 (j).
    Will IRC Section 163(J) help companies under the old rules?This planning would benefit companies under the old rules as well.” The Tax Cuts and Jobs Act amended IRC Section 163 (j) to limit the deduction for net business interest expense in excess of interest income.
    Does IRC 163(J) business interest limit apply?Under the small business exemption, the IRC §163 (j) business interest limitation does not apply to a taxpayer (other than a tax shelter) that satisfies the IRC §448 (c) gross receipts test for any tax year.
    What is a section 163(J) limitation?Pursuant to paragraph (c) (2) of this section, a single section 163 (j) limitation is computed for the specified period ending June 30, Year 1. That section 163 (j) calculation will include FP and FC1's specified taxable years ending May 31, Year 1, and FC2 and FC3's specified taxable years ending June 30, Year 1. (3) Example 3.
    What are IRC Section 163(J) carryforwards?IRC Section 163 (j) carryforwards that arose before January 1, 2018, are carried forward as disallowed qualified interest to the taxpayer's first tax year beginning after December 31, 2017.
    What is a section 163(J) limitation for 2021?A's section 163 (j) limitation for 2021 is $48x ($160x × 30 percent). Thus, all $45x of A's business interest expense incurred in 2021 is deductible in that year. Under paragraph (b) (1) (ii) (C) of this section, A must subtract $30x from its tentative taxable income in computing its ATI for its 2024 taxable year.
     
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