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Debt-Equity Internal Revenue Service Debtor-Creditor

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

Morrison & Foerster LLP

IRS Issues Final Debt-Equity Regulations

Morrison & Foerster LLP on

On October 13th, the Internal Revenue Service (“IRS”) followed through on its promise to issue final regulations and temporary regulations under Section1 385 (the “Final Regulations” and “Temporary Regulations,” respectively)...more

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