HELOC Interest Deduction

[Kyler Pace]

I understand the new rules regarding the tax deductibility of HELOC interest, but I have a situation that isn't quite so straight forward. I have a HELOC and used a portion of it to pay off a silent second mortage on my primary residence. The original silent second was the down payment. So, under the new rules, it was used directly on my primary residence but not to make an improvement, and in a way, it was used to "buy" it, although I didn't just purchase it. Can I still deduct the interest?