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B-333545 Sep 13, 2021 1 (2021-09-13)

handle is hein.gao/gaomev0001 and id is 1 raw text is: 1Oo_ U.S. GOVERNMENT ACCOUNTABILITY OFFICE A Century of Non-Partisan Fact-Based Work 441 G St. N.W. Washington, DC 20548 B-333545 September 13, 2021 The Honorable Ron Wyden Chairman The Honorable Mike Crapo 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: Additional Guidance Regarding 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 Additional Guidance Regarding Limitation on Deduction for Business Interest Expense (RIN: 1545-BP73). We received the rule on January 14, 2021. It was published in the Federal Register as final regulations on January 19, 2021.1 86 Fed. Reg. 5496. The effective date is January 13, 2021. IRS stated that the final rule provides additional guidance regarding the limitation on the deduction for business interest expense under section 163(j) of the Internal Revenue Code (Code), title 26, United States Code, to reflect amendments made by the law commonly known as the Tax Cuts and Jobs Act, Pub. L. No. 115-97, 131 Stat. 2054 (Dec. 22, 2017) and the Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136, 134 Stat. 281 (Mar. 27, 2020). Specifically, IRS stated that the rule addresses the application of the limitation in contexts involving passthrough entities, regulated investment companies (RICs), and controlled foreign corporations. The regulations also provide guidance regarding the definitions of real property development, real property redevelopment, and syndicate. The rule, according to IRS, affects taxpayers that have business interest expense, particularly passthrough entities, their partners and shareholders, as well as foreign corporations and their United States shareholders. The rule also affects RICs that have business interest income, RIC shareholders that have business interest expense, and corporations that are members of a consolidated group. 1 The due date for this major rule report was February 3, 2021. Due to a processing error on our part, we are delayed in our issuance of this report.

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