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.
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
A recent Tax Court case shows the government’s willingness and ability to attack financing arrangements that do not reflect arm’s-length debt standards, even without the forthcoming Section 385 regulations. Our International Tax Group analyzes that case and reviews the IRS’s decision to stop treating some FATCA intergovernmental agreements as “in effect.”