A Note from the Editors-in-Chief

Matthew Mosby is a Partner and Jeffrey Rodrick and Hubert Raglan are Directors with the Financial Institutions & Products Group of the Washington National Tax Practice of KPMG LLP In our next column, 2020 Insurance Tax Review, Christopher W. Schoen and Graham R. Green provide a review of insurance tax developments during 2020. The authors describe the changes made to the anti-avoidance rule from the Code Sec. 163(j) regulations proposed in 2018 to the final regulations, as well as the broader changes to the definition of interest for purposes of Code Sec. 163(j) when the regulations were finalized (e.g., the removal of certain interestequivalent transactions from the definition of interest). The authors then consider what these changes might mean for the scope of the anti-avoidance rule, including whether the anti-avoidance rule applies only when a taxpayer attempts to reduce interest for purposes of Code Sec. 163(j) or if the anti-avoidance rule might also apply when a taxpayer seeks to reduce interest expense as an ec-mic manner (for example, by choosing nondebt financing alternatives that provide a lower cost of funds).