The American Institute of CPAs (AICPA) has made more than 20 recommendations to the US Treasury and Internal Revenue Service (IRS) about the initial guidance governing the deduction of business interest expense by certain large businesses, as amended by the Tax Cuts and Jobs Act (TCJA).

In Notice 2018-28, Initial Guidance Under Section 163(j) as Applicable to Taxable Years Beginning After December 31, 2017, Treasury and IRS described the rules they expect to issue and requested comments about the additional guidance that taxpayers will need to compute the business interest expense limitation under Internal Revenue Code (IRC) section 163(j).

The AICPA said it will be submitting a second comment letter on the interaction of the proposed guidance note with international tax provisions.