Article Title

Economic Partiality and Horizontal Inequity: The New TCJA Interest Expense Deduction Limit

Publication Title

Washington University Journal of Law & Policy


The Tax Cuts and Jobs Act significantly overhauled the federal tax code. This included a limit on the amount of interest that a business can deduct, which ended the prior policy of full deductibility. This implicates policy questions regarding a corporation’s decision of how to structure how much debt and equity it holds. Viewing this through the considerations of horizontal equity and economic neutrality, this Note proposes to reverse this limitation or to permit full deductibility of disallowed deductions upon maturity of the debt.