Page 218 - Large Business IRS Training Guides

IRC § 163(j) Limitation Applied to Foreign

Persons with Effectively Connected Income (ECI)

• IRC §163(j) applies to the interest expense of

Foreign Persons with effectively connected

income.

• Section 1.163(j)-8 of the proposed regulations

provides the rules for determining the amount

of Adjusted Taxable Income, Business Interest

Income, Business Interest Expense, and Floor

Plan Financing Interest Expense and

calculating the IRC § 163(j) limitation for

Foreign Persons with ECI.

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