Page 88 - Large Business IRS Training Guides

Old vs. New IRC § 163(j) 1

Old IRC § 163(j) New IRC § 163(j)

• Intended to prevent earnings • Intends to prevent over-

stripping. reliance on debt.

• Applied only to corporations • Applies to all taxpayers,

that did not meet a debt except small businesses and

equity ratio safe harbor. certain trades or businesses.

• Proposed regulations were • Proposed regulations were

issued in 1991 but never issued in Dec. 2018 and are

finalized. in the process of being

finalized.

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