Treasury Issues Final Controversial Debt-To-Equity Rules

Law360, Washington (October 13, 2016, 7:54 PM EDT) -- The U.S. Treasury Department issued its final debt-to-equity rules Thursday, with changes to exempt certain kinds of corporations, employee stock plans and others from regulations meant to curb the tax benefits of corporate inversions.

A Treasury statement said the final rules would "balance the operational needs of companies while preventing the erosion of our U.S. corporate tax base," by exempting foreign subsidiaries of multinationals, S-corporations, mutual funds, real estate investment trusts and transactions between banks from a regime that would allow the IRS to treat transactions as part debt and part equity when calculating taxes, rather than wholly one or the...

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