lunes, 11 de abril de 2016

Proposed Regulations Addressing Treatment of Certain Interests in Corporations as Stock or Indebtedness

On 4 April 2016, the US Treasury and the IRS published broadly applicable proposed regulations under Code section 385 that would (i) authorize the IRS to treat certain related-party interests as part stock and part debt for federal tax purposes; (ii) establish contemporaneous documentation requirements that must be satisfied for certain related-party debt to be respected for federal tax purposes; and (iii) treat certain related party debt as stock for all purposes of the Code when issued in connection with certain distributions and acquisitions.

Source & more info: Deloitte

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