On 28 March 2019, the U.S. Joint Committee on Taxation (JCT) published an overview of the limitation on the deduction of business interest expense under Section 163(j) of the Internal Revenue Code as introduced by the Tax Cuts and Jobs Act. The new rule applies to taxable years beginning after 31 December 2017 and generally limits the amount of a taxpayer’s business interest deduction to the sum of the taxpayer’s business interest income; 30% of the taxpayer’s adjusted taxable income; and the floor plan financing interest of the taxpayer.
Any business interest expense in excess of this threshold is carried forward to the following year. The limitation generally does not apply to small businesses (other than tax shelters), regulated public utilities, and electing farming or real property trades or businesses.
