Glossary/Tax and regulatory

Section 163(j) interest limitation

Section 163(j) limits the business interest deduction to business interest income plus 30 percent of adjusted taxable income, carrying disallowed interest forward, with an exemption for small businesses under the gross receipts test.

CORAA TeamUpdated November 5, 2026

Definition

Section 163(j) caps the business interest expense a taxpayer may deduct in a year at the sum of business interest income, 30 percent of adjusted taxable income (ATI), and floor plan financing interest. Interest above the cap is treated as paid or accrued in the next year, so it carries forward. A taxpayer that meets the gross receipts test of section 448(c) is exempt. For tax years beginning after 2024, ATI again adds back depreciation, amortization and depletion, which raises the cap compared with the 2022 through 2024 years. The calculation is reported on Form 8990.

Why it matters in an audit or review

Highly leveraged clients can have disallowed interest that affects current tax, creates a deferred tax asset, and may need a valuation allowance. Auditors recompute ATI, test the small business exemption, and agree the carryforward to the prior-year return. Loan covenants use different definitions, so they do not substitute for the tax calculation.

Example

Illustrative: ATI is $2,000,000, business interest income is $50,000, and interest expense is $700,000. The limit is $50,000 + (30% x $2,000,000) = $650,000. Disallowed interest is $50,000. At an assumed 25% rate, the deferred tax asset is $12,500.

Common mistakes

  • Using the ATI definition from the wrong year.
  • Assuming a small business is exempt without testing the three-year average gross receipts.

Sources

  • Internal Revenue Code section 163(j), subsections (1), (2), (3) and (8): https://www.law.cornell.edu/uscode/text/26/163
  • Treasury Regulations sections 1.163(j)-1 through 1.163(j)-11
  • IRS, Instructions for Form 8990
  • FASB ASC 740-10-30, Initial measurement

Definitions paraphrase AICPA and FASB guidance; read the standard itself before relying on a requirement. Example figures are illustrative. This page is guidance, not professional advice. Report an error

Standards

IRC 163(j)ASC 740

Related terms

  • Deferred tax assets and liabilities
    Deferred tax assets and liabilities capture the future tax effects of temporary differences between book and tax bases, measured at enacted tax rates under ASC 740 and classified as noncurrent.
  • Valuation allowance
    A valuation allowance reduces a deferred tax asset to the amount more likely than not to be realized, based on positive and negative evidence about future taxable income.
  • Book-tax differences
    Book-tax differences arise when GAAP income differs from taxable income because of timing items that reverse and permanent items that never do, reconciled on Schedule M-1 or M-3.

Go deeper

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