Date Start Date: 3/17/2025 Start Time: 3:00 PM EST End Date: 3/17/2025 Contact Name: Luke Rogers Email
Any taxpayer that has paid Michigan or Pennsylvania corporate income tax as a consequence of applying the federal interest expense limitation under IRC § 163(j) may be entitled to a refund. Federal IRC § 163(j) limits a taxpayer’s net interest expense to 30% of taxable income (with adjustments). The Michigan Department of Treasury and Pennsylvania Department of Revenue take the position that the limitation applies to their respective corporate income taxes, and that taxpayers must compute the limit on a separate-company basis. This separate-company application differs from the consolidated limitation most taxpayers apply on their federal return, and can be particularly detrimental for taxpayers that borrow externally or manage group financing from a company with limited operations. This separate-company application is particularly problematic in Michigan because the state requires combined reporting. But, there may be a solution. Join us for a short webinar on Monday March 17 to hear why Michigan and Pennsylvania are arguably prohibited from applying 163(j)’s interest expense limitation. We’ll also tell you how to protect your refund rights. This is important because the statute of limitations to claim a refund on the basis that the states are prohibited from conforming to the limitation is shorter than the typical refund statute in most states: another year closes for calendar-year taxpayers on March 31 in Michigan, and May 16 in Pennsylvania. Visit the Website
