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December 31, 2017 SECTION 1. PURPOSE

Initial Guidance Under SECTION 163(j) as Applicable to Taxable Years Beginning After December 31, 2017 Notice 2018 -28 SECTION 1. PURPOSE This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue proposed regulations providing guidance to assist taxpayers in complying with SECTION 163(j) of the Internal Revenue Code (Code), as amended on December 22, 2017, by An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018 , 115-97 (the Act). This notice further describes certain of the rules that those proposed regulations will include to provide taxpayers with interim guidance as more comprehensive guidance is developed.

- 6 - receipts, which was added by section 14401 of the Act. The regulations will provide that business interest carried forward from a taxable year beginning before January 1, 2018,

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