Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-memo-section-163j-interest-deductibility.docx
tax-memo-section-163j-interest-deductibility.docx
Parties
HARKNESS LLP
Nexford Industrial Holdings Inc
Structure Nexford Industrial Holdings Inc
Canada Business Corp
Adjusted Taxable Inc
Estimated Business Interest Inc
Estimated Taxable Inc
Kendrick LLP
Dates
March 5, 2025
December 31, 2021
December 31, 2024
March 28, 2032
June 30, 2025
March 28, 2025
October 15, 2028
January 1, 2022
December 31, 2025
September 30, 2025
Amounts
$1,400,000,000
$117.7
$1,393,000,000
$3,500,000
$250,000,000
$18,125,000
$135.8
$130,000,000
$150,000,000
$385,000,000
Obligations
The limitation applies on an annual basis, and the computation must be performed each taxable year based on the taxpayer's actual results of operations for that year
Because the Section 163(j) analysis is being performed on a prospective basis prior to the close of FY 2025, we must estimate taxable income based on available financial data and reasonable assumptions