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Interest Expense for Purposes of IRC § 163(j)
Anti-Avoidance Rule
Interest expense includes:
• Any otherwise deductible expense or loss
for an amount predominantly incurred in
consideration of the time value of money,
• Incurred in a transaction or series of
integrated or related transactions, and
• In which the taxpayer secures the use of
funds for a period of time.
• Prop. Treas. Reg. § 1.163(j)-1(b)(20)(iv)
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