Syndicate Rules May Create Problems for Small Businesses and §163(j) Interest Limits
An exception to the general rule that small businesses are exempt from the §163(j) limits on the deduction for business interest applies to any entity that is a “tax shelter.” The most likely problem to arise that many may not initially notice is that the organization might meet the definition of a syndicate.
On January 11, 2019, Tax Notes Today published a story that featured comments from Tony Nitti, CPA that discussed the potential issues that may arise with the interest deduction limitation under §163(j) and the syndicate rules.
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