July 1, 2016
International Tax Co-Leader Doug Nakajima authored an article about new Section 385 regulations governing the classification of corporate debt, for Bloomberg BNA's Daily Tax Report.
Bloomberg BNA
Excerpt:
The Treasury Department and the Internal Revenue Service proposed new regulations April 4 under tax code Section 385 (REG-108060-15). Although announced as part of the ongoing effort to curb corporate inversions, the proposed regulations focus on related-party corporate indebtedness and, if made effective without significant changes, will have far-ranging impact on corporate ownership and capital structures well beyond the inversion-focused motivation.
The new rules will have implications to the treatment of corporate interests in the targeted cross-border environment, but also in a number of purely domestic situations.
