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The Interest Expense Dilemma: Breaking Down IRC 163j Limitations – Featuring: Estefania Cabrera, Senior Tax Associate

Tax planning can make or break your business strategy, and nowhere is this more evident than with interest expense deductions. In this eye-opening episode of Knowing What Counts, Senior Tax Associate Estefania Cabrera unravels the complex world of IRC Section 163J limitations – rules that could significantly impact how much of your business interest expense you can actually deduct.

Originally targeting foreign-owned companies using U.S. subsidiaries to lower tax bills through interest deductions, the Tax Cuts and Jobs Act of 2017 expanded these limitations to most U.S. businesses. We break down exactly how these rules work: limiting business interest deductions to 30% of adjusted taxable income plus 100% of business interest income. But who's affected? Estefania explains the small business exemption for companies with average gross receipts under $31 million and special elections available for farming and real estate businesses.

The conversation takes a practical turn as we explore how these limitations affect different entity types. For corporations, the process is straightforward with limitations applied and tracked at the corporate level. Partnerships face more complexity, with excess interest passed through to partners who must then track these amounts themselves. We also discuss a critical change after 2022 – the elimination of the depreciation add-back provision that creates a counterintuitive situation where taking more depreciation can actually reduce allowable interest deductions.

Avoid common pitfalls we see clients encounter: incorrectly assuming exemption status, partners losing track of excess interest carry-forwards, and businesses failing to properly combine related entities' gross receipts. Whether you should slow down depreciation, capitalize interest expenses, or elect out of limitations entirely depends on your specific situation. The key takeaway? These rules change annually with inflation adjustments, so staying connected with your tax advisor is crucial for effective planning. Don't wait until tax filing time to discover these limitations – by then, it's too late to implement strategic changes.

Visit TheMPGroupCPA.com or call 413-739-1800 to speak with our tax experts about optimizing your business interest deductions while remaining fully compliant with evolving tax regulations.

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