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Debt SALT

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

McDermott Will & Emery

SALT Implications of Proposed Section 385 Debt/Equity Regulations

McDermott Will & Emery on

Determining the difference between debt and equity is a problem that has bedeviled taxpayers and tax administrators for decades. Taxpayers, recognizing that there are tax advantages to financing a corporation with debt (e.g.,...more

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