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  2. In general, it limits a taxpayer’s interest expense deductions for a taxable year to the sum of 30 percent of adjusted taxable income (ATI) and its business interest income. Certain taxpayers involved in the sale of motor vehicles may also be able to increase their section 163 (j) limitation by any floor plan financing interest expense.
    www.mwe.com/insights/section-163j-interest-expen…
    Under section 163 (j) (1), the amount allowed as a deduction for BIE is limited to the sum of (1) the taxpayer's business interest income (BII) for the taxable year; (2) 30 percent of the taxpayer's adjusted taxable income (ATI) for the taxable year (30 percent ATI limitation); and (3) the taxpayer's floor plan financing interest expense for the taxable year (in sum, the section 163 (j) limitation).
    www.federalregister.gov/documents/2021/01/19/20…
    If section 163(j) applies to you, the business interest expense deduction allowed for the tax year is limited to the sum of: 1. Business interest income, 2. 30% of the adjusted taxable income, and 3. Floor plan financing interest expense. Carryforward of disallowed business interest.
    www.irs.gov/pub/irs-prior/i8990--2018.pdf
    Section 163 (j) limits the deduction of business interest to the sum of a taxpayer’s business interest income, floor plan financing interest, and 30% of its ATI for a given taxable year. The CARES Act modified the limitation to 50% of ATI for tax years beginning in 2019 and 2020 (partnerships have special rules).
    www.grantthornton.com/insights/alerts/tax/2021/fla…
    The Sec. 163 (j) limitation applies to any interest properly allocable to a trade or business. For corporations that are partners in a partnership (or members of a limited liability company (LLC) taxed as a partnership), the limitation applies first at the partnership level and again at the partner and shareholder level.
    www.thetaxadviser.com/issues/2019/sep/limiting-b…
     
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    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.
    What is a section 163(J) deduction?The newly enacted version of section 163 (j) limits deductions for business interest expense. In general, it limits a taxpayer’s interest expense deductions for a taxable year to the sum of 30 percent of adjusted taxable income (ATI) and its business interest income.
    How does section 163(J) affect business interest deductions?As such, taxpayers should assess their positions under Section 163 (j) considering the new regulations in tandem with existing guidance. Section 163 (j) limits the deduction of business interest to the sum of a taxpayer’s business interest income, floor plan financing interest, and 30% of its ATI for a given taxable year.
    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).
     
  4. Basic questions and answers about the limitation on the …

     
  5. Sec. 163(j) business interest limitation: New rules for …

    WEBDec 1, 2022 · After providing some background on the Sec. 163(j) business interest limitation, this item discusses how the rules for calculating ATI have changed for 2022 and beyond and how this affects the deductibility limit.

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