Illinois DOR Proposes Amendments to Foreign Affiliate Interest Addback Rules

April 29, 2026, 3:42 PM UTC

The Illinois Department of Revenue (DOR) proposed amendments to 86 IAC 100.2430 regarding addition and subtraction modifications for transactions with 80/20 and noncombination rule companies for income tax purposes. The proposed regulations implement changes from Public Act 104-6, which modified provisions requiring taxpayers to add back deductions for interest and intangible expenses paid to foreign persons conducting 80 percent or more of their business outside the United States. The proposed rules also repeals certain exceptions to the addition modification requirements for both interest and intangible expenses. Comments on the proposed regulations are due June 8. [Ill. Dep’t of Revenue, Proposed ...

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