The recently released regulations under Internal Revenue Code Section 385, addressing the circumstances under which related company debt will be classified as equity for federal income tax purposes, will have a significant impact on not only federal taxes but also on state and local taxes. For a more detailed discussion of these implications by our own Peter Faber, please see here.
SALT Implications of Final Section 385 Debt-Equity Regulations
By McDermott Will & Emery on October 27, 2016
Posted In IRS Guidance, Uncategorized