On May 13, 2020, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) released regulations finalizing previously proposed regulations under Internal Revenue Code Section 385 regarding the...more
On Nov. 4, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final debt-equity regulations (the Final Regulations) and an advance notice of proposed rulemaking (the...more
11/18/2019
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bifurcation ,
Controlling Stockholders ,
Debt ,
Debt-Equity ,
Debtor-Creditor ,
Distribution Rules ,
Equity ,
Identity of Interest ,
IRS ,
New Regulations ,
Regulatory Standards ,
Rulemaking Process ,
Section 385 ,
Stocks ,
Tax Liability ,
Tax Planning ,
U.S. Treasury