Carried forward interest loses its capitalized character
To provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70341, Sec. 70341.
Written by .
Carried forward interest loses its capitalized character
The document says “shall not”Who acts: Secretary of the TreasuryHow: statuteSec. 70341 in the PDF
What the document says
“Such term shall not include any interest which is capitalized under section 263(g) or 263A(f).”
The section provides that no part of business interest carried forward under paragraph (2) to a later year is treated for any purpose of the title, including any interest capitalization provision that applied to it before, as interest to which such a provision applies. It defines an interest capitalization provision as any provision of the subtitle under which interest must be charged to capital account or may be deducted or charged to capital account. It also adds a sentence to section 163(j)(5) taking interest capitalized under section 263(g) or 263A(f) out of business interest.
What the document actually says
“Such term shall not include any interest which is capitalized under section 263(g) or 263A(f).”
That sentence, in plain words
The term leaves out some interest. That is interest added to what an asset cost. Two rules in the tax code name it.
What this is about
Interest carried into a later year also changes. It stops counting as added to cost. That holds for the whole tax code.
No action is recorded against this proposal. That is not evidence that none has been taken, and nobody has yet read it against the record. See what the tracker does not yet cover.
Provide for reconciliation pursuant to title II of H. Con. Res. 14, Public Law 119-21, sec. 70341, 139 Stat. 207 (2025). https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
This page
“Carried forward interest loses its capitalized character,” Provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70341, Sec. 70341. Read the Mandate, https://readthemandate.org/pl-119-21/proposal/sec70341-carryforward/ (retrieved August 26, 2026).
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