By Mark Leeds and Brennan Young ( July 10, 2018, 5:59 PM EDT) -- The deduction for interest has been under some pressure lately. The Tax Cuts and Jobs Act amended Section 163(j) of the Internal Revenue Code to place substantial limitations on the ability of all taxpayers to deduct "business interest."[1] Thus, costs and expenses of obtaining credit that are deductible but are not treated as interest expense are particularly attractive to borrowers. On June 22, 2018, the Internal Revenue Service issued Chief Counsel Memorandum 20182502F,[2] advising that a borrower in a lending transaction is entitled to deduct unused commitment fees as ordinary business expenses. The memorandum provides a short road map for borrowers to take advantage of this treatment in other lending transactions....