investment interest limitations

Russian translation: ограничения на суммы вычитаемых расходов, связанных с инвестиционными капиталовложениями

15:56 May 1, 2019
English to Russian translations [PRO]
Investment / Securities
English term or phrase: investment interest limitations
However, that portion of interest expense allocable to portfolio investments is subject to the investment interest limitations.
esperansa2016
Ukraine
Russian translation:ограничения на суммы вычитаемых расходов, связанных с инвестиционными капиталовложениями
Explanation:
ИМХО полное название investment interest expense limitation

Under pre-TCJA law and still under current law, interest expense that is utilized to create investment (non-trade or business) income is subject to the investment interest expense limitation of IRC Sec. 163(d). This limits the amount of interest expense that a partner in an investment partnership can deduct on his personal income tax return to the amount of investment income earned. For example, if an investor fund utilizes a margin account and pays interest on it, the fund will separately report this interest expense to its investors on the schedule K-1. The partners are then required to calculate how much investment income they have earned that year to determine if they can deduct the interest expense allocated to them. If a taxpayer is invested in multiple funds, they aggregate all of the investment income to determine if they can utilize the interest expense to offset their income. Although trader funds are considered to be in a trade or business, the income they generate is primarily investment type income. However, if the law did not specifically include the trader income in the definition of investment income, the interest expense utilized to generate trader fund income would be deductible without limitation. In order to bring parity in the investment world, Congress included in the definition of investment income, a limited partner’s share of a trader fund’s income, which then makes the interest expense allocated to a limited partner in a trader fund subject to the investment interest expense limitation. The interest expense allocated to the general partner of a trader fund is generally not subject to the investment interest expense limitation. This is because of the language in IRC Sec. 163(d)

https://www.eisneramper.com/interest-expense-limitation-rule...
Selected response from:

Mikhail Zavidin
Local time: 13:17
Grading comment
Selected automatically based on peer agreement.
4 KudoZ points were awarded for this answer



Summary of answers provided
3 +2ограничения на суммы вычитаемых расходов, связанных с инвестиционными капиталовложениями
Mikhail Zavidin
4ограничения процентных ставок по инвестициям
interprivate
3ограничения инвестиционного дохода
Vladyslav Golovaty


  

Answers


12 mins   confidence: Answerer confidence 4/5Answerer confidence 4/5
ограничения процентных ставок по инвестициям


Explanation:
IMO

interprivate
Local time: 10:17
Native speaker of: Native in RussianRussian, Native in UkrainianUkrainian
PRO pts in category: 4
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1 hr   confidence: Answerer confidence 3/5Answerer confidence 3/5 peer agreement (net): +2
ограничения на суммы вычитаемых расходов, связанных с инвестиционными капиталовложениями


Explanation:
ИМХО полное название investment interest expense limitation

Under pre-TCJA law and still under current law, interest expense that is utilized to create investment (non-trade or business) income is subject to the investment interest expense limitation of IRC Sec. 163(d). This limits the amount of interest expense that a partner in an investment partnership can deduct on his personal income tax return to the amount of investment income earned. For example, if an investor fund utilizes a margin account and pays interest on it, the fund will separately report this interest expense to its investors on the schedule K-1. The partners are then required to calculate how much investment income they have earned that year to determine if they can deduct the interest expense allocated to them. If a taxpayer is invested in multiple funds, they aggregate all of the investment income to determine if they can utilize the interest expense to offset their income. Although trader funds are considered to be in a trade or business, the income they generate is primarily investment type income. However, if the law did not specifically include the trader income in the definition of investment income, the interest expense utilized to generate trader fund income would be deductible without limitation. In order to bring parity in the investment world, Congress included in the definition of investment income, a limited partner’s share of a trader fund’s income, which then makes the interest expense allocated to a limited partner in a trader fund subject to the investment interest expense limitation. The interest expense allocated to the general partner of a trader fund is generally not subject to the investment interest expense limitation. This is because of the language in IRC Sec. 163(d)

https://www.eisneramper.com/interest-expense-limitation-rule...

Mikhail Zavidin
Local time: 13:17
Works in field
Native speaker of: Native in RussianRussian
PRO pts in category: 76
Grading comment
Selected automatically based on peer agreement.

Peer comments on this answer (and responses from the answerer)
agree  Igor Volosyanoy
13 hrs
  -> Спасибо!

agree  Erzsébet Czopyk
16 hrs
  -> Спасибо!
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12 mins   confidence: Answerer confidence 3/5Answerer confidence 3/5
ограничения инвестиционного дохода


Explanation:


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Note added at 20 hrs (2019-05-02 12:01:15 GMT)
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возможность вывода доходов, полученных от инвестиций, а также ... Это ограничение не действует, если речь идет о выплате ... https://inventure.com.ua/analytics/formula/kakie-osobennosti...

Vladyslav Golovaty
Ukraine
Local time: 12:17
Native speaker of: Native in EnglishEnglish, Native in RussianRussian
PRO pts in category: 12

Peer comments on this answer (and responses from the answerer)
neutral  Erzsébet Czopyk: дохода?
18 hrs
  -> см. выше
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