Section 163j and the proposed regulations provide a new level of complexity for taxpayers with respect to their financing structure. This session will provide an overview of the section 163j rules for corporations and partnerships, and an overview of the interplay of section 163j with other tax reform provisions such as the BEAT and GILTI. This session will also highlight the nuances of section 163j that should be considered in debt financing structures.
Identify the basic rules of section 163(j) for partnerships and corporations.
Apply the ordering rules with respect to section 163(j) and other tax-reform related provisions.
Determine points to consider in each taxpayers debt financing structure.