The IRS this afternoon released an advance version of Rev. Proc. 2020-22 as guidance for purposes of the business interest expense deduction limitation under section 163(j):
Rev. Proc. 2020-22 [PDF 54 KB] allows certain taxpayers to make a late election—or to withdraw an election—under section 163(j)(7)(B) or 163(j)(7)(C) on an amended federal income tax return, an amended Form 1065, or an administrative adjustment request (AAR) under section 6227.
The revenue procedure reflects recent changes made to section 163(j)(10) by Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (Pub. L. No. 116-136).
Rev. Proc. 2020-22 describes the time and manner in which certain taxpayers can elect:
The purpose of this report is to provide text of the revenue procedure.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.