[20200601]IN11287_《冠状病毒援助、救济和经济安全（CARES）法案》规定的企业利息扣除限额.pdf

CRS INSIGHT Prepared for Members and Committees of Congress INSIGHTINSIGHTi i Limits on Business Interest Deductions Under the Coronavirus Aid, Relief, and Economic Security (CARES) Act Updated June 1, 2020 Thin capitalization rules, broadly, limit the amount of debt that can generate deductible interest for the purpose of calculating taxable income. Limits on the tax deduction for business interest restrictions have been relaxed by the Coronavirus Aid, Relief, and Economic Security (CARES) Act (H.R. 748, as amended) providing economic stimulus and relief for taxpayers due to the expected slowdown of the economy because of the coronavirus pandemic. These restrictions, also referred to by their Internal Revenue Code Section 163(j), were expanded by the 2017 tax revision, P.L. 115-97. Changes in P.L. 115-97, Popularly Known as the “Tax Cuts and Jobs Act (TCJA)” Restrictions on net interest deductions were significantly tightened in the 2017 tax legislation. Taken as a whole, the tax revision was a tax cut, although a number of provisions were enacted to limit certain deductions, among them the restrictions on interest deductions. Rules Prior to TCJA Prior to the TCJA, the thin capita