A Practical Method For Utility Property Interest Allocation

By Bradley Seltzer, Amish Shah and Engin Nural (June 20, 2018, 4:18 PM EDT) -- Under Section 163(j) of the Internal Revenue Code, as amended by the recent tax reform bill, interest deductions are limited but certain exceptions are provided, including interest paid in the business of providing electric, water, gas or steam if the rates charged for such service are subject to review and approval by a regulatory body on a cost of service/rate of return basis.[1] Because these businesses are frequently conducted by organizations that are part of a group of corporations or other entities, the statute requires that the taxpayer determine the interest expense that is "properly allocable to" its Section 163(j) exempt and non-exempt activities....

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