Topic
Interest Deductions
16 published works
Tax Talks
Tax Relief for American Families and Workers Act of 2024
By David S. Miller, Richard M. Corn, Jo Habenicht, Kathleen R Semanski, Martin T. Hamilton, Amanda H. Nussbaum
On January 17, 2024, Senate Finance Committee Chairman Ron Wyden (D-Ore.) and House Ways and Means Committee Chairman Jason Smith (R-Mo.) released a bill, the “Tax Relief for American Families…
Louisiana Law Blog
When to Challenge the Denial of an Interest Expense Deduction in Louisiana
By Jaye Calhoun, Sean McLaughlin, William Kolarik
Louisiana Department of Revenue income tax auditors are increasingly proposing large assessments by misapplying a formula in a Department regulation (La. Admin. Code 61:I.1130(B); the “Regulation”). The Regulation is based…
Disputing Tax
Updated Interest Deductibility Guidance Released by the IRS under Section 163(j)
On July 28, 2020, the Treasury Department and the IRS issued final and proposed regulations (the “Final Regulations” and “New Proposed Regulations”) under Section 163(j) of the Internal Revenue Code…
Tax Controversy Posts
The Sins of the Father: Interest, Deductions, and Inherited Assets
At one time the Internal Revenue Code permitted a deduction for any interest, but that changed long ago.While section 163 of the Code still says that “[t]here shall be allowed…
International Financial Law Prof Blog
Tax Reform Current Developments Dec 27, 2018
IRS Releases Proposed Regulations on 163(j) Interest Deduction LimitsThe IRS has released proposed regulations on the limitations that the 2017 tax reform package placed on the business interest expense deduction.…
Legacy Advisors
Proposed Regulations on the Interest Deduction Limitation Under Section 163(j) of the Internal Revenue Code
On Nov. 26, 2018, the IRS issued proposed regulations under the Internal Revenue Code (IRC) § 163(j) enacted by the Tax Cuts and Jobs Act of 2017 (the Proposed Regulations).…
GT Amsterdam Law Blog
Another Interest Deduction Limitation Rule in Dutch Corporate Income Tax Law
As part of global and European initiatives against tax avoidance, all EU member states are required to incorporate the EU Anti-Tax Avoidance Directive (ATAD) into domestic tax law no later…
Take Stock: Federal Policy Watch
Tax Policy Update: May 15, 2018
By Lai K. Lam
The full edition of this week's Tax Policy Update is up - read it here. Previous editions are available in the links below: May 8, 2018 April 24, 2018 April…
Tax Controversy 360
Tax Takes Video: Changes to Interest Deduction
By John T. Lutz, McDermott Will & Emery
The Senate and House bills include provisions that place limitations on interest deductions for corporations. McDermott Tax partners Alexander Lee and John Lutz discuss several implications for US and US-based…
Tax
Disallowance of Deduction for Interest Paid to Hungarian Affiliate Serves as a Reminder of Department’s Continued Audit Scrutiny of Intercompany Debt
By Michael A. Jacobs, Robert E. Weyman, Brent K. Beissel, Sebastian C. Watt
A case recently resolved at the Appellate Tax Board serves as a reminder that Massachusetts’ auditors continue to aggressively challenge the following intercompany transactions: Interest deductions for interest paid to…