IRS Casting 'Wide Net' With Debt-Equity Regs, Attys Say
By Bryan Koenig (October 13, 2016, 4:30 PM EDT) -- In both timespan and scope, the U.S. Department of the Treasury and the Internal Revenue Service are casting a "wide net" with proposed new regulations that would treat debt between related entities in international transactions as stock not entitled to tax advantages, Mayer Brown LLP attorneys said Thursday.
In a teleconference organized by Mayer Brown to discuss the proposed regulations, tax transactions & consulting practice partners Russell Nance and Steven Garden pointed to aspects of the proposal — floated as part of a larger plan to curb corporate inversions overseas and proposed under Section 385 of the Internal Revenue Code —...
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