IRC Section 385

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Tax Notes Select is a one-time purchase giving you access to a handpicked collection of articles containing news and analysis on your chosen tax topic. When the IRS and the U.S. Treasury Department on April 4, 2016, issued proposed regulations to address earnings stripping under IRC section 385, tax practitioners began attempting to understand the potential ramifications. It seemed that Treasury was using the proposed regulations to curb the use of inversions by recharacterizing certain related-party financings as equity.
    This collection contains the following articles:
  • "SALT Implications of Final Section 385 Debt-Equity Regulations"
  • "News Analysis: Banks Win Relief From Final Debt-Equity Rules"
  • "Treasury's Debt-Equity Regulations Miss the Big Challenge"
  • "News Analysis: U.S. Treasury Doubles Down on Inbound Planning"
  • "Some Practitioners Want More Rationale for Debt-Equity Regs"
  • "Major Debt-Equity Reg Changes and More Reaction"
  • "Debt-Equity Reg Package Includes Broad Carveouts"
  • "Administration Exceeds Its Power With New Inversion Regs"
  • "U.S. Chamber of Commerce Files Suit Challenging Inversion Regs"
  • "Treasury Considering Changing Debt-Equity Regs in 4 Big Areas"
  • "News Analysis: Uncertainties and Costs of the Debt-Equity Regs"
  • "Proposed Debt-Equity Regulations: What Problem Are We Solving?"
  • "News Analysis: Debt-Equity Regs: Treasury's Options"
  • "News Analysis: Challenging U.S. Anti-Inversion Guidance"
  • "News Analysis: Inversion Regs Will Push States to Tackle Complex Questions"
  • "Inversion Regs, Debt-Equity Rules May Not Be Finalized Together"
  • "News Analysis: Treasury Goes After Earnings Stripping, Hits Cash Management"
  • "The Broad Reach of the New Earnings-Stripping Regulations"
  • "News Analysis: Proposed Earnings Stripping Regs Cast Wide Net"
  • "Temp Inversion Regs Go Further Than Notices, May Derail Deals"
  • "U.S. Treasury Moves on Earnings Stripping, Further Attacks Inversions"
  • "Treasury's Unfinished Work on Corporate Expatriations"
  • "U.S. Treasury Takes Action Against Inversions"
  • "Mr. Secretary, Take the Tax Juice Out of Corporate Expatriations"
  • "News Analysis: What Can Treasury Do About Inversions?"