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  2. Sec. 163(j) provides that the amount allowed as a deduction under [Chapter 1] for business interest expense may not exceed the sum of: Business interest income for a taxable year; Floor plan financing interest for such taxable year; and 30% of "adjusted taxable income" for such taxable year.
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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.
    What is a section 163(J) limitation?A18. The section 163 (j) limitation applies at the consolidated return level, and a consolidated group has a single limitation. In calculating the limitation, a consolidated group's business interest expense and business interest income is, respectively, the sum of its members' business interest expense and business interest income.
    Does section 163(J) apply to business interest expenses?Section 163 (j) and the regulations in this part under section 163 (j) of the Code generally apply only to business interest expense that would be deductible in the current taxable year without regard to section 163 (j).
     
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    WEBDecember 1, 2022. Editor: Carolyn Quill, CPA, J.D., LL.M. Co-editors: Richard Mather, E.A., MSA, CAA; Jonathan McGuire, CPA; and Kathleen Moran, CPA, MBA, MT. The business interest expense deductibility …

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