Wednesday, November 9, 2016
David S. Miller (Proskauer, New York) & Janicelynn Asamoto Park (Proskauer, New York), IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385:
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain debt instruments as equity for all federal income tax purposes. This paper briefly describes the final and temporary regulations.
Politico Morning Tax, What's Next on 385