# Prop. Treas. Reg. § 1.163-15: Debt Proceeds Distributed from Any Taxpayer Account or from Cash.

Proposed regulation, not in force. REG-106089-18, 85 FR 56846, published 2020-09-14 <https://www.federalregister.gov/documents/2020/09/14/2020-16532/limitation-on-deduction-for-business-interest-expense-allocation-of-interest-expense-by-passthrough>. Interprets 26 U.S.C. § 163.

Par. 3. Section 1.163-15 is added to read as follows:

(a) In general. Regardless of paragraphs (c)(4) and (5) of § 1.163-8T, in the case of debt proceeds deposited in an account, a taxpayer that is applying § 1.163-8T or § 1.163-14 may treat any expenditure made from any account of the taxpayer, or from cash, within 30 days before or 30 days after debt proceeds are deposited in any account of the taxpayer as made from such proceeds to the extent thereof. Similarly, in the case of debt proceeds received in cash, a taxpayer that is applying § 1.163-8T or § 1.163-14 may treat any expenditure made from any account of the taxpayer, or from cash, within 30 days before or 30 days after debt proceeds are received in cash as made from such proceeds to the extent thereof. For purposes of this section, terms used have the same meaning as in § 1.163-8T(c)(4) and (5).

(b) Applicability date. This section applies to taxable years beginning on or after [DATE 60 DAYS AFTER DATE OF PUBLICATION OF THE FINAL RULE IN THE FEDERAL REGISTER ]. However, taxpayers and their related parties, within the meaning of sections 267(b) and 707(b)(1), may choose to apply the rules of this section to a taxable year beginning after December 31, 2017, and before [DATE 60 DAYS AFTER DATE OF PUBLICATION OF THE FINAL RULE IN THE FEDERAL REGISTER ], provided that they consistently apply the rules of this section to that taxable year and each subsequent taxable year.