Treasury and the IRS released Notice 2018-28 (the Notice) on April 2, 2018. The Notice provides interim guidance and describes proposed regulations that they intend to issue on the limitation on business interest expense deduction under amended Section 163(j) for tax years beginning after December 31, 2017.
The Notice identifies issues that the proposed regulations will cover, but specifically addresses several of the uncertainties with which taxpayers have been grappling since Section 163(j) was amended. These issues include:
The Notice also provides that until proposed regulations are issued, taxpayers may rely on the rules set forth in the Notice.