Federal Tax

Deduction Limitations: General (Portfolio 504)

  • Related Party Transactions examines and analyzes the dual purposes of §267, a central related party provision.


Bloomberg Tax Portfolio, Deduction Limitations: General, No. 504, analyzes deduction limitations. For deduction limitations that are the subject of other Portfolios, the description provides an overview and an introduction to the terminology and substantive requirements of the statutory or other provision that applies. For the other deduction limitations the provision is analyzed in depth.

The analysis of the deduction limitations is organized according to the type of deduction. These include computational limitations, reflection of other tax benefits, capitalization restrictions, public policy grounds, and personal expenses.

Table of Contents

I. Introduction
II. Computational Limitations
III. Deductions Disallowed Because of Other Tax Benefit
IV. Deductions Disallowed on Account of Capitalization Rules
V. Public Policy Restrictions
VI. Disallowance of Personal Deductions
VII. Deductions Disallowed Because of Relationships
VIII. Other Deduction Disallowances

James Maule
Professor of Law, Emeritus
Villanova University School of Law