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- To permit limiting DD&A Add-Back Recapture to sales (or other dispositions) of property at a gain, the 2021 Final Regulations authorize limitation of DD&A Add-Back Recapture to the lesser of (i) any gain recognized on the sale of the property, and (ii) the greater of the DD&A allowed or allowable for the taxpayer with respect to the property during the EBITDA Period.15 Applying this taxpayer-favorable limitation is not compulsory; the 2021 Final Regulations call it an alternative computation method, and it is available if the taxpayer applies this computation method to all of its DD&A Add-Back Recapture calculations.16rsmus.com/insights/tax-alerts/2021/additional-section-163-j-final-regulations-rele…
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Sec. 163(j) business interest limitation: New rules for 2022
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