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Internal Revenue Code (IRC) Intercompany Transactions Internal Revenue Service

Whiteford

Understanding IRS Encouragement of PLRs for Healthcare Entities and Assessing Healthcare Corporate and Tax Structure For Tax...

Whiteford on

The IRS has recently been urging healthcare entities, particularly those involving physicians and private investors, to seek private letter rulings (PLRs) to clarify the tax implications of their ownership structures. This...more

Morgan Lewis

Impact of New Tax Regulations on Intercompany Debt Obligations

Morgan Lewis on

The final, temporary, and proposed regulations issued by the Internal Revenue Service on October 13 relating to intercompany debt obligations between members of an affiliated group of corporations under Section 385 of the...more

Eversheds Sutherland (US) LLP

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Recently proposed Treasury regulations under IRC ยง 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

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