As part of the Tax Cuts and Jobs Act (“TCJA”) signed into law on December 22, 2017, some important changes have been made with respect to the deductibility of business interest expense for tax years beginning after December 31, 2017. Under prior law, business interest expense was generally deductible in the year in which the interest was paid or accrued, except that corporations were subject to certain limitations under IRC Section 163(j) (“the earnings stripping rules”). TCJA created a new limitation, which replaces the “earnings stripping rules” and applies to all businesses, regardless of form, on the deductibility of net business interest expense that exceeds 30% of a taxpayer’s “adjusted taxable income.” Read More

Monika Miles

Businesses obviously grow by selling their products outside of their local boundaries and across state lines. Pennsylvania (PA) has experienced, like most states, a relatively large amount of sales from companies outside PA, and, with that, the loss in sales tax revenue from those sales, as out of state companies do not often collect sales tax. Pennsylvania has a growing economy, and like most states, it is continually modifying its tax laws to be current with changing conditions and technologies.

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The new law in brief

An important Bill affecting foreign investors into Australia was passed by the Australian Parliament, 25 September 2014, – the ‘Tax and Superannuation Laws Amendment (2014 Measures No. 4) Bill 2014’.

It affects two areas of taxation in Australia – tax deductibility of financing expenses in an international context, and the taxation of dividends in Australia received from abroad.

This note deals with the tax deductibility of financing expenses – the so-called ‘thin cap’ rules. (It does not deal with the thin cap rules applicable to financial entities and banks). Read More