
Section 7872 and the AFR Trap: How an Informal Family Loan Triggers Imputed Interest and Gift Tax
Informal family or employer loans below the AFR trigger IRC Section 7872 imputed interest, treated as gifts, wages, or dividends.
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Calculate and track interest income and expenses

Informal family or employer loans below the AFR trigger IRC Section 7872 imputed interest, treated as gifts, wages, or dividends.

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.

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