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Inaugural Partnership Tax Matters Alert

July 2, 2019

The Tax Cuts Jobs Act of 2017 made numerous changes to the federal income tax law which have a significant impact on the taxation of partnerships and their partners. One area of particular importance which has yet to be fully clarified is the manner in which the business interest limitation of Code Section 163(j) is applied in the partnership context. The Treasury Department has issued proposed regulations under Code Section 163(j) which, while providing much needed guidance, also leave several key issues unresolved. The following article provides a detailed analysis of the business interest limitation of Code Section 163(j) and its application in the partnership context.


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