Page 227 - Large Business IRS Training Guides

Ordering Rules

Step 3: Determine if taxpayer is subject to other

provisions that affect the disallowance, deferral or other

limitation of interest. (Precede IRC § 163(j) limitation)

For example:

• Interest capitalized as part of self-constructed assets-

IRC § 263A

• Related party interest deferral - IRC § 267(a)(2) & (3)

• Interest in Hybrid transactions/entities - IRC § 267A

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