§163(j) small business exception
Under the small business exemption, the IRC §163(j) business interest limitation does not apply to a taxpayer (other than a tax shelter) that satisfies the IRC §448(c) gross receipts test for any tax year. Generally, the gross receipts test is satisfied if the taxpayer’s average annual gross receipts for the three prior tax years are less than or equal to $25,000,000 (adjusted annually for inflation after 2018).
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