In light of the rapidly changing coronavirus (COVID-19) situation, Troutman Sanders and Pepper Hamilton have postponed the effective date of their previously announced merger until July 1, 2020. The new firm – Troutman Pepper – will feature 1,100+ attorneys across 23 U.S. offices. Read more.
Presented by the American Bar Association Section of Taxation
The Treasury Department and the IRS have issued proposed regulations addressing the business interest expense deduction limitation under section 163(j), as amended by the 2017 Tax Act. A wide range of taxpayers and their U.S. businesses are now subject to the rules under section 163(j) and its effects are far reaching. Taxpayers with significant business interest expense will want to consider these rules when engaging in merger and acquisition activity, making borrowings, planning internal restructurings, reporting financial results, and preparing tax returns.
Although the limitation formula appears simple, its application as set out in the statute and the proposed regulations thereunder is very complex. Many of the rules apply differently to different entity types, even to and within a group of affiliated and related corporations. Adding to the complexity are the questions that remain unaddressed and the new questions raised by the published guidance.
This webinar addresses the application of section 163(j) to affiliated and related corporations. Key topics will include:
CLE credit available.
ABA Section of Taxation Members: $75
ABA Members: $150