Baker McKenzie's North America Tax Practice Group has prepared a Tax News and Developments Client Alert on the proposed regulations under section 163(j) that were released on November 26, 2018. The Client Alert provides a high level overview of the voluminous regulations and offers a more detailed discussion of select issues which taxpayers have been concerned about since Congress enacted section 163(j), including how section 163(j) applies to CFCs, consolidated groups, partnerships, etc. 

Please do not hesitate to contact the indicated authors of the alert or any member of our North America Tax Practice Group if you would like additional information or for further discussion of the issues addressed.

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