Interest Expense Deductions (Portfolio 536)
The Portfolio Interest Expense Deductions describes in detail the basic rules relating to the allowance of and limitations on deductions for interest expenses as set forth in §163(a).
Bloomberg Tax Portfolio, Interest Expense Deductions, No. 536, describes in detail the basic rules relating to the allowance of and limitations on deductions for interest expenses as set forth in the Internal Revenue Code and Treasury Regulations. Coverage includes: (1) the determination of whether payments are interest in form but not in substance, or vice versa; (2) the measurement and timing of interest deductions; (3) the investment interest limitation; (4) the nondeductibility of personal interest, including the “qualified residence interest” exception; (5) the various provisions for imputation of interest, including imputation of interest on certain types of below-market loans; (6) the interest capitalization rules; and (7) a survey of provisions disallowing interest.
Table of Contents
II. Outline of Legislative History
III. What Is “Interest?”
IV. Is It Interest in Form But Not in Substance?
V. Is It Interest in Substance Although Not in Form?
VI. Accounting Issues
VII. Who Is Paying the Interest?
VIII. How Is Interest Classified?
IX. Imputed Interest
X. Special Statutory Disallowances and Deferrals
XI. Alternative Minimum Tax
XII. Tax Deficiency Interest
Associate Vice President, Tax Compliance And Internal Audit
University Of San Francisco