Page 146 - Large Business IRS Training Guides
P. 146
Allocation Rules - General
Before allocating between excepted and non-excepted
trades or businesses, interest under IRC § 163(j), taxpayer
must:
• Determine if the taxpayer meets the small business
exemption.
• Determine the amount of interest expense allocated
between investment, personal, and other.
• Identify excepted trades or businesses.
Limitation under IRC § 163(j) does not apply to interest
expense properly allocable to an “excepted trade or
business.”
76