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Manufacturers Internal Revenue Service Anti-Inversion Regulations

Foley & Lardner LLP

Attention Taxpayers: New IRS Rules May Deem Debt to Be Stock

Foley & Lardner LLP on

In April, the IRS proposed rules that would treat debt between related corporations as stock for U.S. tax purposes. These rules would apply to all corporations (including regular C corporations, S corporations, foreign...more

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