The Shearman & Sterling Tax team hosted a two-part discussion about the recently issued final regulations under Code Section 163(j) on August 19th and August 20th. Part 1, presented by partners Ryan Bray, Larry Crouch, Kristen Garry, Jay Singer, Nate Tasso provided an overview of Section 163(j) (including an analysis of what items are considered interest subject to limitation) and the key provisions in the final regulations relating to corporations and non-U.S. taxpayers. Part 2, presented by partners Todd Lowther and Mike Shulman, counsel Derek Kershaw and associate Julia Pashin provided a detailed analysis of the portions of the Section 163(j) final regulations relating to interest paid byPa partnerships and the applicability of the limitation to interest expense attributable to certain excepted businesses (including regulated utilities and electing real property businesses).
Originally published 22 August, 2020
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