On February 26 MLPA  filed comments on the proposed regulations issued by the IRS under section 163(j) of the tax code. Section 163(j), enacted in 2017 as part of the Tax Cut and Jobs Act, limits the amount of business interest expense that may be deducted by taxpayers. MLPA’s comments focus on fungibility issues and the characterization and treatment of guaranteed payments, issues of particular importance to MLPs.  To see the text of the comments, click here.