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Publication 17
taxmap/pub17/p17-121.htm#en_us_publink1000173295

Investment Interest(p158)

rule
This section discusses interest expenses you may be able to deduct as an investor.
If you borrow money to buy property you hold for investment, the interest you pay is investment interest. You can deduct investment interest subject to the limit discussed later. However, you cannot deduct interest you incurred to produce tax-exempt income. Nor can you deduct interest expenses on straddles.
Investment interest does not include any qualified home mortgage interest or any interest taken into account in computing income or loss from a passive activity.
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Investment Property(p158)

rule
Property held for investment includes property that produces interest, dividends, annuities, or royalties not derived in the ordinary course of a trade or business. It also includes property that produces gain or loss (not derived in the ordinary course of a trade or business) from the sale or trade of property producing these types of income or held for investment (other than an interest in a passive activity). Investment property also includes an interest in a trade or business activity in which you did not materially participate (other than a passive activity).
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Partners, shareholders, and beneficiaries.(p158)

rule
To determine your investment interest, combine your share of investment interest from a partnership, S corporation, estate, or trust with your other investment interest.
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Allocation of Interest Expense(p158)

rule
If you borrow money for business or personal purposes as well as for investment, you must allocate the debt among those purposes. Only the interest expense on the part of the debt used for investment purposes is treated as investment interest. The allocation is not affected by the use of property that secures the debt.
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Limit on Deduction(p158)

rule
Generally, your deduction for investment interest expense is limited to the amount of your net investment income.
You can carry over the amount of investment interest that you could not deduct because of this limit to the next tax year. The interest carried over is treated as investment interest paid or accrued in that next year.
You can carry over disallowed investment interest to the next tax year even if it is more than your taxable income in the year the interest was paid or accrued.
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Net Investment Income(p159)

rule
Determine the amount of your net investment income by subtracting your investment expenses (other than interest expense) from your investment income.
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Investment income.(p159)

rule
This generally includes your gross income from property held for investment (such as interest, dividends, annuities, and royalties). Investment income does not include Alaska Permanent Fund dividends. It also does not include qualified dividends or net capital gain unless you choose to include them.
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Choosing to include qualified dividends.(p159)
Investment income generally does not include qualified dividends, discussed in chapter 8. However, you can choose to include all or part of your qualified dividends in investment income.
You make this choice by completing Form 4952, line 4g, according to its instructions.
If you choose to include any amount of your qualified dividends in investment income, you must reduce your qualified dividends that are eligible for the lower capital gains tax rates by the same amount.
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Choosing to include net capital gain.(p159)
Investment income generally does not include net capital gain from disposing of investment property (including capital gain distributions from mutual funds). However, you can choose to include all or part of your net capital gain in investment income.
You make this choice by completing Form 4952, line 4g, according to its instructions.
If you choose to include any amount of your net capital gain in investment income, you must reduce your net capital gain that is eligible for the lower capital gains tax rates by the same amount.
Deposit
Before making either choice, consider the overall effect on your tax liability. Compare your tax if you make one or both of these choices with your tax if you do not.
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Investment income of child reported on parent's return.(p159)

rule
Investment income includes the part of your child's interest and dividend income that you choose to report on your return. If the child does not have qualified dividends, Alaska Permanent Fund dividends, or capital gain distributions, this is the amount on line 6 of Form 8814, Parents' Election To Report Child's Interest and Dividends.
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Child's qualified dividends.(p159)
If part of the amount you report is your child's qualified dividends, that part (which is reported on Form 1040, line 9b) generally does not count as investment income. However, you can choose to include all or part of it in investment income, as explained under Choosing to include qualified dividends, earlier.
Your investment income also includes the amount on Form 8814, line 12, (or, if applicable, the reduced amount figured next under Child's Alaska Permanent Fund dividends).
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Child's Alaska Permanent Fund dividends.(p159)
If part of the amount you report is your child's Alaska Permanent Fund dividends, that part does not count as investment income. To figure the amount of your child's income that you can consider your investment income, start with the amount on Form 8814, line 6. Multiply that amount by a percentage that is equal to the Alaska Permanent Fund dividends divided by the total amount on Form 8814, line 4. Subtract the result from the amount on Form 8814, line 12.
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Child's capital gain distributions.(p159)
If part of the amount you report is your child's capital gain distributions, that part (which is reported on Schedule D, line 13, or Form 1040, line 13) generally does not count as investment income. However, you can choose to include all or part of it in investment income, as explained in Choosing to include net capital gain, earlier.
Your investment income also includes the amount on Form 8814, line 12 (or, if applicable, the reduced amount figured under Child's Alaska Permanent Fund dividends, earlier).
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Investment expenses.(p159)

rule
Investment expenses are your allowed deductions (other than interest expense) directly connected with the production of investment income. Investment expenses that are included as a miscellaneous itemized deduction on Schedule A (Form 1040), are allowable deductions after applying the 2% limit that applies to miscellaneous itemized deductions. Use the smaller of:
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Losses from passive activities.(p159)

rule
Income or expenses that you used in computing income or loss from a passive activity are not included in determining your investment income or investment expenses (including investment interest expense). See Publication 925, Passive Activity and At-Risk Rules, for information about passive activities.
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Form 4952(p159)

rule
Use Form 4952, Investment Interest Expense Deduction, to figure your deduction for investment interest.
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Exception to use of Form 4952.(p159)

rule
You do not have to complete Form 4952 or attach it to your return if you meet all of the following tests. If you meet all of these tests, you can deduct all of your investment interest.
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More Information(p159)

rule
For more information on investment interest, see Interest Expenses in chapter 3 of Publication 550.