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The One Big Beautiful Bill Act makes three major changes to the interest deduction limitation provision of §163(j). Pub. L. No. 119-21, §70303, §70341 (July 4, 2025), applicable to taxable years beginning after December 31, 2024. This article reviews the three changes and then focuses on the new rule for capitalized interest.

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Reproduced with permission from Tax Management International Journal

Author

Sam Pollack is a partner in the Firm’s Global Tax Practice Group in Chicago. He provides domestic and international tax planning advice for corporations and pass-through entities.