Leveraged buyouts run on debt, and debt runs on deductible interest. Section 163(j) caps that deduction at business interest income + 30% of “adjusted taxable income” (ATI). For tax years beginning after 2024, ATI is back to an EBITDA-style measure — depreciation and amortisation are added back again — which made the cap much looser for capital-heavy businesses than it was in 2022–2024.
Disallowed interest isn't lost; it carries forward indefinitely. Smaller businesses under a gross-receipts threshold are exempt, and real estate businesses can elect out in exchange for slower depreciation. In a partnership the test is run at the partnership level and excess amounts are pushed out to partners — which is why your K-1 may carry a line about it.
Worked example
A portfolio company has ATI of $10m and pays $5m of interest on its acquisition debt. It deducts $3m this year; the other $2m carries forward. If EBITDA grows to $20m next year, the cap rises to $6m and some of the carried-forward interest can be used.
Where you'll see it: Buyout models (tax line), Form 8990, and the “excess business interest expense” box on partnership K-1s.
Full explainer: EBITDA vs EBIT →
See all 53 terms in the glossary
This glossary is general information, simplified for learning. It is not tax, legal or investment advice, and real structures turn on facts and documents not shown here.