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26 CFR § 1.163-8T - Allocation of interest expense …
https://www.law.cornell.edu/cfr/text/26/1.163-8T
(1) Debt allocated to capital expenditures - (i) Time of reallocation. Except as provided in paragraph (j) (2) of this... (2) Disposition proceeds in excess of debt. If the proceeds from the disposition of an asset exceed the amount of debt... (3) Special rule for deferred payment sales. If any ...
Tracing Rules That Apply For Deductibility Of Interest
https://www.taxcpe.com/blogs/news/tracing-rules-that-apply-for-deductibility-of-interest
Tracing Rules That Apply For Deductibility Of Interest. Personal interest - is not deductible. Typically this includes interest from personal credit card debt, personal car loan interest, home appliance ... Investment interest – Typically …
Tracing Rules: Tracking the Deductibility of Interest
https://cbmslaw.com/2003/05/31/tracing-rules-tracking-the-deductibility-of-interest/
Basic questions and answers about the limitation on the …
https://www.irs.gov/newsroom/basic-questions-and-answers-about-the-limitation-on-the-deduction-for-business-interest-expense
Real estate industry impact of recent section 163(j) …
https://rsmus.com/insights/tax-alerts/2020/real-estate-industry-impact-of-recent-section-163-j-guidance.html
Section 163(j) limits business interest expense deductions for a taxable year that exceed the sum of 30% (50% in some years) of the taxpayers adjusted taxable income, their business interest income, and their floor plan financing interest.
Deloitte 2020 Interest Tracing Guide
https://www2.deloitte.com/content/dam/Deloitte/us/Documents/Tax/us-tax-deloitte-2020-interest-tracing-guide.pdf
IN THIS SECTION INTEREST TRACING Applying the rules With that as background, how would you apply the interest tracing rules? As an example, assume a taxpayer borrowed from a bank and used the loan proceeds to purchase a boat. Assume that the loan was secured by an investment account held with the bank. It may feel intuitive to determine the
Five types of interest expense, three sets of new rules
https://www.thetaxadviser.com/issues/2018/oct/five-types-interest-expense-new-rules.html
In years before 2018, interest is deductible on acquisition indebtedness up to $1,000,000 for single taxpayers, heads of household, and married taxpayers filing jointly and $500,000 for married taxpayers who file separately. 16 Interest on home - equity indebtedness is deductible to the extent the debt does not exceed the lesser of:
Interest Deduction on Debt-Financed Distributions
https://www.thetaxadviser.com/issues/2007/nov/interestdeductionondebtfinanceddistributions.html
Interest Tracing Rules Under Temp. Regs. Sec. 1.163-8T Generally, interest expense on a debt is allocated in the same manner as the debt to which such interest expense relates is allocated. Debt is allocated by tracing disbursements of the debt proceeds to specific expenditures by partners (i.e., trade or business, investment, passive, etc.).
Internal Revenue Service memorandum - IRS tax forms
https://www.irs.gov/pub/irs-wd/1201017.pdf
163(h)(3) of the 1986 Act, however, permitted deduction of qualified residence interest. Section 163(h)(3) was amended by the Omnibus Budget Reconciliation Act of 1987 (OBRA 1987) to allow a deduction for qualified residence interest for up to $1,000,000 of acquisition indebtedness and $100,000 of home equity indebtedness. Prior to amendment, section 163(h)(3) generally …
Don't Neglect to Elect - Journal of Accountancy
https://www.journalofaccountancy.com/issues/2010/jun/20102639.html
Normally, interest on such indebtedness is treated as an itemized deduction by individual taxpayers under section 163(h)(3). However, by using the interest tracing rules, such taxpayers might elect to treat such debt as not secured by the qualified residence and deduct the related interest expense on Schedule C rather than Schedule A.
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