On 28 December 2018, the US Treasury Department and the US Internal Revenue Service (IRS) published in the Federal Register the proposed regulations (REG-106089-18) that provide guidance on the limitation on the deduction for business interest expense under section 163(j) of the US Internal Revenue Code (IRC) as amended by the Tax Cuts and Jobs Act (TCJA). For a previous report on the proposed regulations.
The proposed regulations are proposed to be effective generally for taxable years ending after the date the final regulations that adopt the proposed regulations are published in the Federal Register. Taxpayers, however, may rely on the rules in the proposed regulations until the final regulations are published.