On 21 September 2020, the US Treasury and the IRS finalized regulations under Section 864(c)(8), generally retaining the basic approach and structure of the proposed regulations issued on 20 December 2018 (REG-113604-18).
In brief The Tax Cuts and Jobs Act of 2017 (Public Law 115-97) (TCJA) made significant changes to Section 163(j) effective for tax years beginning after December 31, 2017. On December 28, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (“Proposed Regulations”) implementing the amendments to Section 163(j)…