New final and temporary regulations under Section 385, addressing the treatment of related-party debt, significantly narrow parts of the controversial proposed regulations released in April.
The proposed regulations were widely perceived as interfering with various ordinary business transactions that involve related parties as well as common treasury management techniques, such as cash pooling.
The new guidance, released on Oct. 13, includes final and temporary regulations (T.D. 9790) intended to deter certain “earnings stripping transactions” that are often used as domestic, international, or state and local tax planning strategies. The regulations are part of the IRS and Treasury’s continued assault on inversion transactions, but also have a broader impact on many transactions both domestic and cross-border.
Join our webcast to learn how these new regulations may affect your organization.
Recognize the purpose and scope of the regulations and how they will affect your organization.
Provide a detailed analysis regarding the technical application of the regulations.
Identify specific provisions that could affect your business, including a discussion regarding the regulatory impact on cash-pooling systems.
Andrew Cordonnier, partner, Washington National Tax Office, Washington D.C.
Jeff Borghino, partner, Washington National Tax Office, Washington D.C.
David Sites, partner, Washington National Tax Office, Washington, D.C.
Jamie Yesnowitz, principal, Washington National Tax Office, Washington, D.C.
Download this webcast presentation.
Please note: CPE credits are not awarded for webcast replay.
Recommended Field of Study: Taxes
Program Level: Overview
Delivery Method: Group-internet
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