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Interest

Everything About Interest

6 articles

Section 7872 and the AFR Trap: How an Informal Family Loan Triggers Imputed Interest and Gift Tax

Below-market loans under IRC Section 7872 generate imputed interest at the Applicable Federal Rate, recharacterized as gifts, wages, or dividends depending on the relationship — here's how the $10,000 floor, the $100,000 cap for gift loans, and a written note at AFR keep intra-family, employer-employee, and shareholder loans out of the tax trap.

Section 163(j) Business Interest Limitation: The 30% ATI Cap and OBBBA's EBITDA Restoration

OBBBA permanently restored the EBITDA-based ATI calculation for Section 163(j) starting in 2025, expanding deductible business interest for capital-intensive companies. A guide to the 30% cap, the ~$31M small business exemption, the 35% syndicate trap, EBIE allocations from partnerships, S-corp differences, and Form 8990 reporting.