The final debt-equity regulations issued on May 13, 2020, finalize proposed section 385 regulations issued in 2016 without any substantive changes to the existing debt-equity regulations, and withdraw the temporary section...more
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
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
Key Points - - The New Regulations do not apply to debt issued by investment partnership funds, including publicly traded partnership funds, or blockers-at least, not now. - The New Regulations can apply to...more