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Internal Revenue Code (IRC) Debt Investment Funds

McDermott Will & Emery

Receiving Debt-Financed Distributions From a QOF: IRS Allows Significant Flexibility (And Some Traps)

Qualified Opportunity Funds (QOFs) offer generous tax incentives but are bound by a complicated set of rules, not to mention the complexity of Subchapter K of the Internal Revenue Code (IRC), as QOFs are typically organized...more

Proskauer Rose LLP

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

Proskauer Rose LLP on

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385. The final and temporary regulations recharacterize certain debt instruments as equity for...more

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