The final, temporary, and proposed regulations issued by the Internal Revenue Service on October 13 relating to intercompany debt obligations between members of an affiliated group of corporations under Section 385 of the...more
11/3/2016
/ Collateralized Debt Obligations ,
Corporate Counsel ,
Foreign Corporations ,
Intercompany Transactions ,
Internal Revenue Code (IRC) ,
IRS ,
Multinationals ,
Parent Corporation ,
Private Equity ,
Proposed Regulation ,
Registered Investment Companies (RICs) ,
REIT ,
S-Corporation ,
Section 385 ,
Stocks
The principal effect of the rules would be to turn virtually any contribution of appreciated property by a US person to a section 721(c) partnership into a taxable gain recognition event.
On August 6, the US Treasury...more