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The New Section 385 Proposed Regulations: No More Alice in Wonderland

On April 4, 2016, the Treasury issued proposed regulations under section 385 of the Internal Revenue Code that, if finalized, would dramatically change the treatment of intercompany debt issued among members of certain corporate groups.

The proposed regulations have been described as “the most significant change to the income tax law ever undertaken via administrative authority.” They fundamentally redefine the extent to which an intercompany instrument will constitute debt, irrespective of whether that group is inverted and who in the group issues it. This special report details these changes while addressing the challenges and considerations that surround them.

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