163(h) (2) defines personal interest as other than interest paid or accured on debt properly allocable to a trade or business, any investment interest
, any passive activity interest and any qualified residence interest.
A noncorporate taxpayer's deduction for investment interest
is limited to the taxpayer's net investment income for the tax year.
If the personal use test is not met, the rental would likely be a passive activity and the interest expense allocated to the rental period would be PAI; the portion (if any) of the interest allocated to personal use might be investment interest
deductible to the extent of net investment income.
163(d)(1) limits the amount of investment interest
deductible by a noncorporate taxpayer to the amount of the taxpayer's net investment income for that tax year.
Interest on debt used to acquire C stock would generally be investment interest
expense and deductible to the extent of the shareholder's investment income.
9)Elections are made on the Form 4952, Investment Interest
Expense Deduction, and can apparently be made by filing two forms, one for regular tax and one for AMT.
in private Chinese companies has not abated, and by bringing only the right types of companies to fund managers, we expect that the success rate for Redwood clients will be high.
Her wireless, consumer and software knowledge support our areas of investment interest
22, 1986: Amortization treated as a separate interest deduction subject to the various provisions relating to interest deductions, such as investment interest
17 (1993), held that investment interest
expense not allowed (i.
163(d)(4)(B)(i), to exclude the "net capital gain" from disposition of investment property from investment income in determining the usability of investment interest
Since a partner in a trading partnership deducts expenses (including the allowable investment interest
expense) as a trade or business expense against AGI, the full benefit of these deductions is gained.