Get IRS 8926 Instructions 2018-2023

Purpose of Form Corporations use Form 8926 to figure the amount of any corporate interest expense deduction disallowed by section 163(j). ... The corporation's debt-to-equity ratio at the end of the tax year does not exceed 1.5 to 1.

A taxpayer who is a U.S. shareholder of an applicable controlled foreign corporation (CFC) that has business interest expense, ha a disallowed business interest expense carryforward, or is part of a CFC group election generally, must attach Form 8990 with Form 5471, Information Return of U.S. Persons With Respect To ...

A taxpayer who is a U.S. shareholder of an applicable controlled foreign corporation (CFC) that has business interest expense, ha a disallowed business interest expense carryforward, or is part of a CFC group election generally, must attach Form 8990 with Form 5471, Information Return of U.S. Persons With Respect To ...

Excepted trade or business. A trade or business does not include: Performing services as an employee. An electing real property trade or business, An electing farming business, or. Certain utility business.

Under an anti-abuse rule, certain amounts predominantly associated with the time value of money also may be treated as interest expense for purposes of section 163(j). Section 1.163(j)-1(b)(20) of the proposed regulations provides additional information on what constitutes interest under section 163(j).

The term real property trade or business means any real property development, redevelopment, construction, reconstruction, acquisition, conversion, rental, operation, management, leasing, or brokerage trade or business.

An S corporation allocates any excess taxable income and excess business interest income to its shareholders on a pro-rata basis. Section 1.163(j)-6 of the proposed regulations provides special rules and defined terms relating to the application of section 163(j) to partnerships and S corporations.

The Section 163(j) limitation applies at the U.S. Parent level to its business interest expense. In computing a U.S. shareholder's ATI, taxable income is reduced by Section 78 gross-ups, Subpart F income, and GILTI inclusions (reduced by any Section 250 deduction).

Section 163(j)(2), as amended by the Act, provides that the amount of any business interest not allowed as a deduction for any taxable year as a result of the limitation in section 163(j)(1) is treated as business interest paid or accrued in the next taxable year and may be carried forward.

Certain utility business. If a pass-through entity is not required to file Form 8990 because it is a small business taxpayer, but a partner or shareholder is required to file Form 8990, the pass-through entity may be requested to provide certain information so that the partner or shareholder can complete their return.