The formulas
- ATI = taxable income computed without business interest, NOL deduction, section 199A deduction and (after 2024) depreciation, amortization and depletion
- Cap = business interest income + 30% x max(ATI, 0) + floor plan financing interest
- Deductible = min(interest expense + carryforward, cap), or all of it if the gross receipts test is met
- Carryforward = disallowed interest
How it works
Section 163(j) limits the business interest deduction to business interest income, 30 percent of adjusted taxable income and floor plan financing interest. The 30 percent piece cannot go below zero. Interest over the cap is not lost: it is treated as business interest paid in the next year.
A taxpayer that meets the section 448(c) gross receipts test is exempt for the year, unless it is a tax shelter barred from the cash method by section 448(a)(3). A taxpayer that is not a corporation or partnership applies the test as if it were one. For tax years beginning after 2024, depreciation, amortization and depletion are added back in ATI again, which raises the cap for asset-heavy businesses. Business interest does not include interest capitalized under sections 263(g) or 263A(f). This tool does not model partnership allocations or the real property trade or business election.
Illustrative figures only. Check the result against your firm's methodology before relying on it.
Common questions
Does the 30 percent apply to net interest or to interest expense?
The cap is business interest income plus 30 percent of ATI. Interest expense above that sum is limited.
How does the carryforward work?
Disallowed interest is treated as business interest paid or accrued in the next year and goes through the same limit again.
Who is exempt?
A taxpayer that meets the section 448(c) gross receipts test. The 2026 threshold is $32,000,000 of three-year average gross receipts.
Sources
- 26 U.S.C. 163, Interest, Legal Information Institute
- IRS Rev. Proc. 2025-32, 2026 inflation adjusted items
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