The November 26, 2018, release by the Internal Revenue Service of proposed regulations (REG-106089-18) related to IRC § 163(j) has provided some clarity for federal income taxpayers. But the regulations’ treatment of federal consolidated groups gives rise to complexities and questions as to how the limitation will operate at the state level. In this Bottom Line videocast Eversheds Sutherland attorneys Todd Betor and Elizabeth Cha discuss:
- an overview of IRC § 163(j)
- key elements of the proposed regulations
- important SALT considerations