On September 19, 2017, the Internal Revenue Service (IRS) issued proposed regulations providing helpful guidance on whether a debt instrument is in “bearer” or “registered” form. (REG-125374-16). While the paradigm debt...more
Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would potentially treat related-party debt, in whole or in part, as equity for U.S. tax purposes. The Proposed Regulations generally apply to...more