Page 135 - Large Business IRS Training Guides

Taxable Income 2

• Taxable Income (TI) follows the definition from IRC § 63

but computed without regard to the application of the IRC

§ 163(j) limitation.

• Must consider almost everything including 263A, loss

limitations, and GILTI.

• Special rules apply to consolidated groups, CFCs,

partnerships, REITs, RICs, S corporations and tax exempt

entities.

• TI computed each year for purposes of IRC § 163(j)

limitation.

• No carryover of excess limitation unlike old IRC § 163(j).

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