163(j) calculation for lender - Spidell

163(j) calculation for lender

Log in to Post

Message Board 163(j) calculation for lender

This topic contains 0 replies, has 1 voice, and was last updated by Mark Smith 2 months, 2 weeks ago.

  • Author
    Posts
  • #165153
    Mark Smith
    Participant

    I have a question on the 163(j) limitation on business interest expense.  I have a client that is a lender (short term to real estate projects) and his income is basically all interest income and points charged up front.  Would this income be considered business interest income?  It seems logical, but if you are in the business of lending, it seems like it might not qualify.  Thanks!