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Question
Is it true that Section 163(j) is a taxpayer-level aggregate calculation which limits the amount of any net BIE (i.e., the excess of BIE over BII) that can be deducted to 30 percent of a taxpayer’s ATI?
AI accountant’s answer:
Yes, that's correct. Section 163(j) of the Internal Revenue Code imposes a limitation on the deduction for business interest expense (BIE) for applicable taxpayers. The limitation, in general, restricts the deduction for net business interest expense (i.e., the excess of BIE over business interest income, or BII) to 30% of the taxpayer's adjusted taxable income (ATI). However, it's essential to note that the limitation applies only to certain taxpayers, generally those with annual gross receipts exceeding a specified threshold. Also, some businesses, like small businesses, certain real property trades or businesses, and certain farming businesses, can be exempt from the Section 163(j) limit if they meet specific qualifications. Keep in mind that specific taxpayers could be subject to different ATI percentages, and tax laws are subject to change, so always refer to the latest information or consult with a tax professional for your specific situation.
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