Section 385

26 U.S. Code § 385 - Treatment of certain interests in corporations ...

26 U.S. Code § 385 - Treatment of certain interests in corporations as stock or indebtedness ; (1) In general ; (2) Notification of inconsistent treatment ; (3) ...

IRC Code Sec. 385 (Treatment of Cetain Interests in Corporations)

Sec. 385 Treatment of certain interests in corporations as stock or indebtedness · Internal Revenue Code of 1986 · SUBTITLE A -- INCOME TAXES · Chapter 1 -- Normal ...

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.

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 ...

Sec. 385 Regs.: Five Key Themes Every Company Needs to Know

385 in an effort to combat earnings-stripping transactions. According to Treasury, the proposed regulations were intended to further limit the ...

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.

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 ...

US - Practical considerations from the final Section 385 regulations

Page 1176 TITLE 26—INTERNAL REVENUE CODE § 385 ... - GovInfo

(as defined in section 383(a)(2)) or net capital loss. (e) Ordering rules for net operating losses, etc. (1) Carryover rules.

California Code, PEN 385

(a) The term “high voltage” as used in this section means a voltage in excess of 750 volts, measured between conductors or measured between the conductor ...

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 ...

Treatment of Certain Interests in Corporations as Stock or ...

In 1969, Congress enacted section 385 to authorize the Secretary of the Treasury (Secretary) to prescribe such regulations as may be necessary ...

Analyses of Section 385 - Treatment of certain interests in ... - Casetext

Congress attempted to address this issue through the enactment of IRC § 385(a) (as part of the Tax Reform Act of 1969), which authorizes the Treasury Department ...

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 ...

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 ( ...

49 CFR Part 385 -- Safety Fitness Procedures - eCFR

§ 385.3 Definitions and acronyms. Applicable safety regulations or requirements means 49 CFR chapter III, subchapter B—Federal Motor Carrier Safety Regulations ...

Section 385 Turns Debt Into Equity - CLA (CliftonLarsonAllen)

These new rules can cause debt to be re-characterized as equity, resulting in the treatment of deductible interest expense as a nondeductible dividend.

Sec. 385 Regulations Impose Intergroup Debt Requirements

If the minimum documentation and information requirements are not met, the EGI is treated as stock. However, the rules of this section apply ...

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 ...