you might want to go to the bottom of the post and then come back to review the following.
this does not take into account IRC 163(j) which could limit the deductible portion of the interest allocated to
business use of the loan (not the amount distributed)
Here are some key points:
It allows businesses to deduct interest paid or accrued on indebtedness, but with limitations.
The provision is particularly important for tax planning, as it influences how businesses manage their interest deductions and financial strategies.
There are exceptions, such as the small business exception, which allows certain taxpayers to bypass these limitations if they meet specific criteria.
Recent regulations have been issued to clarify the application of IRC 163(j) following amendments by the TCJA and the CARES Act.
For more detailed information, you can refer to the official U.S. tax code or consult tax professionals.
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you also have a dbt financed distribution which has its own rules.
Based on the interest tracing rules mentioned above, the deductibility of any interest related to the debt proceeds distributed must be traced to what the proceeds were for. In the case of a pass-through entity, the entity would not be able to determine what the proceeds were used for after they were distributed to the owners, so the pass-through entity would report any interest expense related to distributed proceeds separately under other deductions, and the owner would have to determine the deductibility of that interest expense.
For example, Partnership P refinances a loan for $10,000,000, and $7,000,000 was used to pay off the original loan that was used to purchase an asset. The remaining $3,050,000 was distributed to the entities’ owners. In this example by the general interest allocation rules 70% of the loan proceeds would be allocated to the business. The remaining 30% would be separately stated as debt-financed distribution proceeds; the interest on which would be separately stated on the owners’ K-1s. The deductibility of that additional interest (or lack thereof) would be based on how that money was spent by the owners. If the owners took the distribution and contributed the proceeds to equity in another business, that interest would potentially be deductible. If the owner invested the distributed proceeds in stocks or bonds the interest could be considered investment interest expense on Schedule A of their personal returns, and if the owners used the proceeds for personal expenses the interest expense could be non-deductible interest.
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Another issue is if the distribution reduces an owner's tax basis below zero. That excess becomes a taxable capital gain.
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Consultation with a tax pro would seem appropriate in this circumstance unless the return preparer is confident that they can comply with the proper tax reporting.
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It would seem that you are asking about your personal taxes, however if there is misreporting on the part of the entity that presents problems for you in properly reporting on your 1040. It would seem the debt-financed distribution may not have been properly reported on the entity's tax return, if interest on 100% of the debt was deducted by the business. You also need to determine your tax basis in the entity before the distribution if you still have tax basis afterwards there's nothing to report as to its taxability.
