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Debt Debt-Equity

Pillsbury Winthrop Shaw Pittman LLP

Implementing China’s New Foreign Investment Law, Part Two: Accepting Foreign Loans

The second installment of a series of alerts focusing on practical issues relating to China’s new Foreign Investment Law. The two current models of foreign loans for Foreign Invested Enterprises reflect the Chinese...more

McDermott Will & Emery

New Debt-Equity Regulations Address Certain Gaps, but More Guidance Is Expected

McDermott Will & Emery on

The final debt-equity regulations issued on May 13, 2020, finalize proposed section 385 regulations issued in 2016 without any substantive changes to the existing debt-equity regulations, and withdraw the temporary section...more

Kramer Levin Naftalis & Frankel LLP

Debt-Equity Dashed Expectations: Treasury and the Service Retain Onerous Section 385 Regulations

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

McDermott Will & Emery

SALT Implications of Final Section 385 Debt-Equity Regulations

McDermott Will & Emery on

The recently released final regulations under Internal Revenue Code Section 385, addressing the circumstances under which related company debt will be classified as equity for federal income tax purposes, will have a...more

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