In our post earlier this month dealing with the SC Legislative Update for 2020 we discussed that SC DOR had a draft ruling clarifying SC’s treatment of IRC§ 163(j).  We wanted to provide you with the update that this proposed regulation has been approved and is now final.

This SC Revenue Ruling #21-2 provides that, beginning after 2017, there is no South Carolina business interest tax limitation and no carryforward. Any interest expense that cannot be deducted against income in the year incurred may create a South Carolina net operating loss. Any federal interest expense carryforward allowed for federal income tax purposes is disallowed for South Carolina income tax purposes and is treated as an addition to South Carolina taxable income.

If you are looking for advice or have questions on any of the information found in the update, please reach out to the WR SALT Team.  They are ready and able to assist you.