About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline
LOG IN
LOG IN

B-332546 1 (2020-09-29)

handle is hein.gao/gaobaebuv0001 and id is 1 raw text is: c AO U.S. GOVERNMENT ACCOUNTABILITY OFFICE 441 G St. N.W. Washington, DC 20548 B-332546 September 29, 2020 The Honorable Chuck Grassley Chairman The Honorable Ron Wyden Ranking Member Committee on Finance United States Senate The Honorable Richard Neal Chairman The Honorable Kevin Brady Ranking Member Committee on Ways and Means House of Representatives Subject: Department of the Treasury, Internal Revenue Service: Limitation on Deduction for Business Interest Expense Pursuant to section 801 (a)(2)(A) of title 5, United States Code, this is our report on a major rule promulgated by the Department of the Treasury, Internal Revenue Service (IRS) entitled Limitation on Deduction for Business Interest Expense (RINs: 1545-B073; 1545-BP07). We received the rule on September 14, 2020. It was published in the Federal Register as final regulations on September 14, 2020. 85 Fed. Reg. 56686. The stated effective date of the regulations is November 13, 2020. According to IRS the final regulations provide guidance about the limitation on the deduction for business interest expense after amendment of the Internal Revenue Code by the provisions commonly known as the Tax Cuts and Jobs Act (TCJA), and the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). TCJA, Public Law 115-97, 131 Stat. 2054 (Dec. 22, 2017); CARES Act, Public Law 116-136, 134 STAT. 281 (Mar. 27, 2020). IRS asserts that the final regulations provide guidance to taxpayers on how to calculate the limitation; what constitutes interest for purposes of the limitation; which taxpayers and trades or businesses are subject to the limitation; and how the limitation applies in consolidated group, partnership, international, and other contexts. The Congressional Review Act (CRA) requires a 60-day delay in the effective date of a major rule from the date of publication in the Federal Register or receipt of the rule by Congress, whichever is later. 5 U.S.C. § 801(a)(3)(A). As noted above the final regulations were published in the Federal Register on September 14, 2020; however, the Senate did not receive the final regulations until September 21, 2020. 166 Cong. Rec. S5830 (daily ed. Sept. 23, 2020). To date, the Congressional Record does not reflect the date of the receipt by the House of Representatives. The final regulations have a stated effective date of November 13, 2020, and do not state that IRS found good cause to waive the 60-day delay for any provisions other

What Is HeinOnline?

HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Contact us for annual subscription options:

Contact Us

Already a HeinOnline Subscriber?

Log In

profiles profiles most