Along with the new year came sweeping changes to the Internal Revenue Code of 1986, as amended (the Code), in the form of the Tax Cuts and Jobs Act (the Act). Among other things, the Act purports to lower taxes and simplify the Code. Lowering the corporate tax rate to 21 percent and allowing a 20 percent deduction for “qualified business income” to pass-through entities such as partnerships certainly seem like a good way to meet these objectives. However, the new limitation on the deductibility of business interest seems contrary to this objective, and as we discuss below, isn’t so simple at all.
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