Tag Archives: Section 385

Federal Tax ADVISORY: Stock Acquisition Checklist

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Treasury’s finalized debt/equity regulations under Section 385 run a daunting 517 pages. Our Federal Tax Group supplies a checklist for the transition period to full application of the new regulations.

Click here to read the full advisory.

International Tax Advisory: Treasury Issues Final & Temporary Section 385 Regulations

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Our International Tax Group explores the final debt-equity regulations under Section 385, highlighting significant modifications to the rules proposed last April. While the regulations remain controversial, the final version brings a number of taxpayer-friendly changes, including a reduction in scope and general delay in application.

Alston & Bird’s full International Tax advisory can be found here: www.alston.com/advisories/section-385-regulations 

Federal Tax Advisory: Enjoining Regulations

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Try and try again. Our Federal Tax Group analyzes how the U.S. Supreme Court thwarted a bankers association’s attempt to circumvent the Anti-Injunction Act.

Click here to read the full advisory.