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

Featured Douglas Nakajima, Director, Tax & Business

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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. International Tax

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.

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Featured

Douglas  Nakajima

Douglas Nakajima

International Tax Co-Leader

  • Tax & Business
  • Philadelphia, PA