The IRS and Treasury Department released a package of temporary and proposed regulations on April 4, 2016 ostensibly aimed at further curbing corporate “inversion” transactions. The regulations cover a wide range of tax issues related to inversions but the newly proposed rules governing debt/equity characterization also apply to transactions completely unrelated to inversions. The expansive scope of the new debt/equity rules will have a significant impact on many taxpayers. We expect that the Treasury Department will seek to finalize the regulations before the change in administrations in January 2017.
This memorandum summarizes some of the key aspects of the regulations. We will follow up with a more detailed discussion of the regulations in a subsequent memorandum.
Please see full publication below for more information.
