Stablecoins are commanding increasing attention from global regulators. While the U.K. is moving steadily toward a clearer regulatory framework, the U.S. is advancing federal legislation that could reshape how foreign...more
On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the “Final” or “Temporary” Regulations) under Internal Revenue Code section 385. These regulations, which consist of both temporary...more
On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more