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Corporate Taxes › Expanded Group Instruments (EGIs) › Internal Revenue Code (IRC)

Proskauer - Tax Talks

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

Proskauer - Tax Talks on

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

Orrick, Herrington & Sutcliffe LLP

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity

Orrick, Herrington & Sutcliffe LLP on

On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more

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