News & Analysis as of

Internal Revenue Service Foreign Issuers

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Orrick, Herrington & Sutcliffe LLP

IRS and Treasury Issue Final Regulations Under §385 Classifying Interests in a Corporation

On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the “Final” or “Temporary” Regulations) under Internal Revenue Code section 385. These regulations, which consist of both temporary...more

Cadwalader, Wickersham & Taft LLP

Controversial Debt-Equity Regulations Finalized With Limited Fixes, Concessions and Reservations by Government

On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more

Morrison & Foerster LLP

Negative Interest Rate Consequences

Over the last few months, the financial press has been filled with reports of negative interest rates. For example, on December 18 2014, the Swiss National Bank announced that it would move from a zero percent interest rate...more

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