A Note from the Editors-in-Chief

On July 28, 2020, the IRS and Treasury Department issued long-anticipated final regulations (the Final Regulations) and proposed regulations (the 2020 Proposed Regulations) with respect to the limitation on deductions for business interest expense under Code Sec. 163(j). The authors also highlight a...

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Bibliographic Details
Published in:Journal of Taxation of Financial Products 2020-09, Vol.17 (3), p.3-4
Main Authors: Price, Mark H, Tompkins, Joshua S
Format: Article
Language:English
Subjects:
Accounting firms
Accounting services
COVID-19
Financial institutions
Leasebacks
Leasing
Secured overnight financing rate
SOFR
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Summary:On July 28, 2020, the IRS and Treasury Department issued long-anticipated final regulations (the Final Regulations) and proposed regulations (the 2020 Proposed Regulations) with respect to the limitation on deductions for business interest expense under Code Sec. 163(j). The authors also highlight areas for future guidance and share practical insights on the various considerations taxpayers will need to weigh when deciding whether to apply the 2018 Proposed Regulations, the Final Regulations, or the statute for tax years prior to the effective date of the Final Regulations. Part 1 of this two-part article discusses sale-leasebacks, highlighting the true lease analysis that is fundamental to the characterization of a sale-leaseback transaction and the tax consequences that can result from the potential characterizations of a sale-leaseback transaction.
ISSN:1529-9287