17 Jul.

Navigating interest expense limitations under IRC Section 163(j)

Business Strategy & Tax

Wednesday, 01:00 p.m.  ET | 1 hr
Credits offered: CPE Event language: English

Participants will be able to apply an analytical lens to IRC Section 163(j) and consider tax planning to enhance value and navigate the interest expense limitation effectively.


Key takeaways

Host: Lindsay Wietfeld, partner, Deloitte Tax LLP

Presenters: Jeffery van Gelder, partner, Deloitte Tax LLP
                       Craig Gibian, principal, Deloitte Tax LLP
                       Alexis Morrison-Howe, principal, Deloitte Tax LLP

1.0 Overview CPE credit | Taxes

The Internal Revenue Code (IRC) Section 163(j) was enacted as part of the 2017 Tax Cuts and Jobs Act and provides a general limitation on the deductibility of interest expense. We’ll discuss:

  • Relevant market forces driving increased interest expense limitations
  • Elements that can affect the calculation of the IRC Section 163(j) interest expense limitation
  • Planning for IRC Section 163(j), including tax elections, capital structure considerations, and review of business operations
  • State tax considerations and planning for domestic group interest expense limitations

Meet the speakers

Lindsay Wietfeld

Lindsay Wietfeld

Tax Partner | Mergers & Acquisitions (M&A)

Lindsay is a tax partner in Deloitte Tax LLP’s M&A Transaction Services practice based in Chicago. She has more than 15 years of experience in public accounting, and she spent the last nine years exclusively serving Deloitte’s M&A practice. Lindsay has assisted clients with significant corporate transactions, acquisitions of closely held companies, multijurisdictional due diligence projects, corporate restructuring, and divestiture planning. Her transaction experience spans a wide range of industries including consumer and industrial products, manufacturing, financial services, and transportation/logistics, and she focuses much of her time on corporate/strategic clients. Lindsay also has experience assisting clients in assessing various tax structure alternatives and analysis of tax benefits.

Craig Gibian

Craig Gibian

Principal | Deloitte Tax LLP

Craig has extensive experience assisting clients in their efforts to evaluate complex financial transactions and utilize financial instruments in a tax efficient manner. He focuses on all aspects of the taxation of debt, including equity-linked debt instruments and debt restructurings, as well as the use of derivatives, particularly in the context of investment management and mergers and acquisitions. Craig is currently the chair of the Financial Transactions Committee of the Tax Section of the American Bar Association and is the former chair of the Financial Products Committee of the DC Bar Taxation Section. He is a frequent speaker at programs sponsored by these organizations, as well as the Securities Industry and Financial Markets Association (SIFMA) and Practising Law Institute (PLI). Craig received his bachelor’s degree from Princeton University and JD from Harvard Law School.

Alexis Morrison-Howe

Alexis Morrison-Howe

Managing Director | Deloitte Tax LLP

Alexis focuses on the multistate tax impacts of complex corporate transactions, debt issues, combined reporting, and apportionment. She is a leader in identifying and analyzing the multistate impacts of the Tax Cuts and Jobs Act and is the architect of the firm’s state tax reform technology tool. Alexis is the Jurisdictional Technical Lead for Massachusetts, helping clients navigate issues related to combined reporting, market sourcing, and debt/equity challenges. Alexis previously practiced at Deloitte United Kingdom where she focused on US international tax issues. Alexis is a frequent speaker at programs sponsored by the Council on State Taxation, the Paul J. Hartman State Tax Conference, Tax Executive Institute, and the Massachusetts Bar Association and she has published a number of articles in State Tax Notes. She serves on the Thought Leader Council of the Massachusetts Taxpayers Federation and the Tax Committee of Associated Industries of Massachusetts. Alexis holds a B.A. cum laude in history from Boston University and a JD from Northeastern University School of Law.

Dbriefs resources

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Wednesday, 17 Jul 2024 01:00 p.m. ET
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