February 2021
On January 5, 2021, the U.S. Department of Treasury and the IRS issued new Final Regulations for IRC Section 163(j) (TD 9943) that apply limitations on the deductibility of business interest expense. Proposed Regulations had been issued in November 2018 and Final Regulations with new Proposed Regulations were issued in July 2020. The Proposed Regulations offered additional guidance and they were published in the Federal Register on September 14, 2020.
The Final Regulations adopted in January 2021 mirror the 2020 Proposed Regulations. They are in effect for taxable years beginning on or after the date 60 days after publication of the Final Regulations in the Federal Register. Entities may retroactively apply the 2021 Final Regulations to taxable years beginning after December 31, 2017, and before the 2021 Final Regulations are otherwise consistently applied.
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