![]() See Regulations section 1.163(j)-3 for additional information on interactions of section 163(j) with other code provisions relating to interest expense. Section 163(j) applies after any basis limitation and before the operation of the at-risk, passive activity loss, or excess business loss limitations. If a safe-harbor election is made for a CFC group, Form 8990 does not need to be filed for each CFC group member, but Form 8990 must be filed for the CFC group.Īn expense that has been disallowed, deferred, or capitalized in the current tax year, or which has not yet been accrued, is not taken into account for section 163(j) purposes. ![]() See Regulations section 1.163(j)-7(b).įor a CFC group, an additional Form 8990 must be filed for the CFC group to report the combined limitations of all CFC group members. shareholder of an applicable controlled foreign corporation (CFC) that has business interest expense, disallowed business interest expense carryforward, or is part of a CFC group must generally apply section 163(j) to the applicable CFC and attach a Form 8990 with each Form 5471. ![]() A taxpayer (including, for example, an individual, corporation, partnership, S corporation) with business interest expense a disallowed business interest expense carryforward or current year or prior year excess business interest expense must generally file Form 8990, unless an exclusion from filing applies.Ī pass-through entity allocating excess taxable income or excess business interest income to its owners must file Form 8990, regardless of whether it has any interest expense.Ī regulated investment company that pays section 163(j) interest dividends (see Regulations sections 1.163(j)-1(b)(22)(iii)(F) and 1.163(j)-1(b)(35)) must file Form 8990.Ī taxpayer that is a U.S.
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