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From 2018 through 2021, the limit was set at 30 percent of EBITDA. As of the beginning of this year, the net interest deduction limitation tightened to 30 percent of EBIT, dropping depreciation and amortization from the calculation.
The deduction for business interest is limited under Sec. 163(j) to the sum of (1) business interest income; (2) 30% of adjusted taxable income (which after 2021, does not include depreciation or amortization); and (3) floor plan financing interest.
The applicable percentage is generally 30% (30% ATI limitation). However, under the CARES Act, the applicable percentage for tax years beginning in 2019 and 2020 is 50%, instead of 30%, of your ATI (50% ATI limitation). The 50% ATI limitation does not apply to partnerships for tax years beginning in 2019.
The limit applies to all taxpayers except a small business with average annual gross receipts for the three prior tax years that do not exceed a threshold amount ($27 million for 2022 and $29 million for 2023).
The Interest Limitation Rule (ILR) is intended to limit base erosion using excessive interest deductions. It limits the maximum net interest deduction to 30% of Earnings Before Interest, Taxes, Depreciation, Amortization (EBITDA). Any interest above that amount is not deductible in the current year.
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Any business interest expense that was disallowed in 2021 due to the limitation is carried forward to 2022 and will no longer be subject to the limitation in 2022. Therefore, you do not need to compute the section 163(j) limitation for the 2022 taxable year.
163(j), a businesss deduction for interest is now limited to the sum of: Business interest income; 30% of the adjusted taxable income (50% for 2019 and 2020, per the CARES Act);3 and. Floor plan financing interest specific financing related to the acquisition of inventory.
Currently, the tax deduction for interest expense is limited to 30 percent of adjusted taxable income (ATI).
Limitation on deduction of business interest Under federal law, every business, regardless of its form, is generally subject to a disallowance of a deduction for net interest expense in excess of 50% of the businesss adjustable taxable income. California does not conform.
Any business interest expense that was disallowed in 2021 due to the limitation is carried forward to 2022 and will no longer be subject to the limitation in 2022. Therefore, you do not need to compute the section 163(j) limitation for the 2022 taxable year.

form 8990 2021