Skip to main content
HelloBooks.ai home

Section 163(j) Business Interest Limit: EBITDA Is Back | HelloBooks Depreciation and amortization are added back to adjusted taxable income again from 2025. Who is exempt and how to rerun the Form 8990 math.

Business returns · Form 8990

The business interest limit goes back to an EBITDA base

For tax years beginning after 2024, depreciation, amortization and depletion are added back when computing adjusted taxable income. Leveraged clients that were limited in 2022 to 2024 may now deduct more interest, and carryforwards may free up.

Free Plan with invoices within 200 transactions, bills & quotes — no credit card.

Business returns · Form 8990

Small business exemption (2025 gross receipts test)

$31 million

ATI base
EBITDA again
Applies
Tax years beginning after 2024
Form
8990

Applies: Tax years beginning after 2024From IRS.gov · checked October 10, 2026

What changed

Under the 2022 to 2024 rules, adjusted taxable income was computed without adding back depreciation, amortization or depletion, which shrank the 30% limit for capital-heavy businesses. The Form 8990 instructions confirm those add-backs return for tax years beginning after 2024.

Businesses with average annual gross receipts of $31 million or less for 2025 remain exempt from the limit, subject to the usual tax shelter exclusion.

Clients to rerun

Pull every client that filed Form 8990 for 2022, 2023 or 2024.

  • Equipment-heavy businesses carrying large depreciation, especially those now taking 100% bonus.
  • Real estate and leveraged acquisitions with disallowed interest carryforwards.
  • Partnerships, where excess business interest expense passes to partners.

Keep interest and depreciation clean in the books

The new computation leans on accurate depreciation and interest totals. Keep loan interest in its own expense account and record loan payments split between principal and interest rather than as a single outflow, so the Form 8990 inputs come straight from the trial balance.

FAQ

Frequently asked questions

Does the EBITDA add-back apply to 2024 returns?
No. It applies to tax years beginning after 2024.
Who is exempt from the 163(j) limit?
Generally, businesses meeting the gross receipts test, which is $31 million of average annual gross receipts for 2025, as long as they are not tax shelters.

Sources

General information for tax professionals, not advice on a specific return. Figures are from IRS.gov on the date shown; check the current IRS instructions before filing.

Start automating your books today

Free Plan with full access to the AI accountant — no credit card, no time limit.

Subscribe to our newsletter

Stay up to date with the latest news and announcements. No credit card required.

By subscribing, you agree to our Privacy Policy.