- Corporate Debt|Equity Considerations and Section 385 Regulations🔍
- IRC Code Sec. 385 🔍
- 26 U.S. Code § 385🔍
- 26 CFR § 1.385|1🔍
- Sec. 385 Regs.🔍
- New Section 385 regulations treating certain related|party corporate ...🔍
- Sec. 385. Treatment Of Certain Interests In Corporations As Stock Or ...🔍
- Removal of Section 385 Documentation Regulations🔍
Sec. 385 Regs.
Corporate Debt-Equity Considerations and Section 385 Regulations
The current Section 385 regulations provide rules that recharacterize as stock certain debt issued in distributions and other related-party transactions.
IRC Code Sec. 385 (Treatment of Cetain Interests in Corporations)
section 385, Treatment of certain interests in corporations as stock or indebtedness. IRC section 385 grants Treasury authority to prescribe such regulations as ...
26 U.S. Code § 385 - Treatment of certain interests in corporations ...
(1) In general ; (2) Notification of inconsistent treatment ; (3) Regulations.
26 CFR § 1.385-1 - General provisions. - Law.Cornell.Edu
This section and §§ 1.385-3 through 1.385-4 (collectively, the section 385 regulations) provide rules under section 385 to determine the treatment of an ...
Sec. 385 Regs.: Five Key Themes Every Company Needs to Know
The new regulation package contains some of the most complex and detailed rules that Treasury has issued in decades.
New Section 385 regulations treating certain related-party corporate ...
Section 385(a) authorizes Treasury to issue regulations that may be necessary or appropriate to determine whether an interest in a corporation is treated as ...
Sec. 385. Treatment Of Certain Interests In Corporations As Stock Or ...
Treatment Of Certain Interests In Corporations As Stock Or Indebtedness. I.R.C. § 385(a) Authority To Prescribe Regulations —. The Secretary is authorized ...
Removal of Section 385 Documentation Regulations
This document removes final regulations setting forth minimum documentation requirements that ordinarily must be satisfied in order for ...
New Debt-Equity Regulations Address Certain Gaps | McDermott
Section 385 authorizes the IRS and the Treasury to issue regulations to determine whether an interest in a corporation may be treated as debt or ...
Section 385 debt-equity regulations finalized; status quo maintained
The regulations under section 385 include recast rules that apply to certain debt instruments issued by members of an expanded group of ...
1 Temporary Regulations under Section 385 on the Treatment ... - IRS
Temporary Regulations under Section 385 on the Treatment of Certain Interests in. Corporations as Stock or Indebtedness. Notice 2019-58.
Sec. 385 Regulations Impose Intergroup Debt Requirements
In October 2016, the IRS issued temporary and final regulations under Sec. 385 providing rules for the characterization of related-party debt instruments.
The Slow Death of the Section 385 Regulations - tax controversy 360
The Slow Death of the Section 385 Regulations ... Internal Revenue Code (Code) Section 385 provides that the US Department of the Treasury ( ...
On July 7, 2017, Treasury released Notice 2017-38, which specifically identified, among others, the Section 385 regulations as candidates for simplification or ...
385(a): “The Secretary is authorized to prescribe such regulations as may be ... literal language of the section 385 regulations by modifying proposed ...
IRS Finalizes Section 385 Earnings Stripping Regulations
The Final Regulations will apply only to instruments issued by members of an expanded group that are domestic corporations for federal income tax purposes.
Final Debt/Equity Regulations - Weil Tax BLOG
The “debt/equity” regulations under Section 385 provide that the IRS may recast related-party debt instruments as equity interests in certain circumstances.
DEBT-EQUITY REGULATIONS UNDER SECTION 385 - Tax Notes
DEBT-EQUITY REGULATIONS UNDER SECTION 385 -- WITHDRAWAL OF T.D. 7747.
Treasury Proposes Section 385 Distribution Regulations - BDO USA
Section 385 of the Code authorizes the Secretary to prescribe rules to determine whether an interest in a corporation is treated as stock or indebtedness (or as ...
Overview of Code Sec. 385 Debt-Equity Regulations - Income Taxes
2016-45, 540). The regulations established threshold documentation requirements that must be satisfied in order for certain related-party interests in a ...