I am treating it as interest expense under 163(j), based on this.
iv) Anti-avoidance rule for amounts predominantly associated with the time value of money. Any expense or loss, to the extent deductible, incurred by a taxpayer in a transaction or series of integrated or related transactions in which the taxpayer secures the use of funds for a period of time is treated as interest expense of the taxpayer if such expense or loss is predominantly incurred in consideration of the time value of money.
This rule is designed to prevent transactions that are essentially financing transactions from avoiding the application of Code Sec. 163(j).