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Sunday, October 23, 2016

Section 385 Regulations Issued - Not as Harsh as The Proposed Regulations

Earlier this year, the IRS issued proposed regulations on the conversion of purported related party debt to equity - see the discussion here. The IRS has now issued temporary and final regulations on the subject.

Taking into consideration the negative comments that came out against the proposed regulations, the IRS has eliminated or softened some of the more negative aspects of the proposed regulations.

The regulations are quite lengthy - the Treasury Decision is over 500 pages. More to follow, once I have given them a read through.

T.D. 9790

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