Proposed regulations under section 163(j) released to Federal Register

The U.S. Treasury Department and IRS this afternoon released for publication in the Federal Register proposed regulations (REG-106089-18) relating to section 163(j) as amended by the new U.S. tax law to disallow a deduction for certain business interest expenses.

Read the proposed regulations [PDF 707 KB] (120 pages) as eventually published in the Federal Register on December 28, 2018. Comments are due by a date that is 60 days after December 28, 2018. A public hearing has been scheduled for February 27, 2019.

The IRS and Treasury provided a version of these proposed regulations on November 26, 2018. KPMG previously provided a report of initial impressions about these proposed regulations (based on the November 2018 version). Read TaxNewsFlash

Advance version of proposed regulations

The version of the proposed regulations released on November 26, 2018, included a note that the proposed regulations had been submitted to the Federal Register for publication; that such publication was pending; and that the version of the proposed regulations released on November 26 “… may vary slightly from the published document if minor editorial changes are made during the [Federal Register] review process. The document published in the Federal Register will be the official document.”

Read a computer-generated document [PDF 13 MB] (an unofficial document produced by KPMG) that compares the 449-page version of the proposed regulations that was submitted to the Federal Register for publication (released on December 20, 2018), with the 439-page version of the proposed regulations released by the IRS on November 26, 2018.

This document is intended to show what changes, if any, have been made to the proposed regulations prior to publication in the Federal Register. It has not been reviewed for accuracy. 

Legend: Omitted text is shown as stricken, new text is indicated by the blue highlight, and replaced text is highlighted in orange.

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