Final §385 Regulations Apply to CFC Loans to Domestic Corporations



Lowell Yoder wrote this bylined article on new final Section 385 regulations regarding debt obligations of domestic corporations to related controlled foreign corporations (CFCs). “It is critical to avoid such debt being reclassified as stock under the regulations because of the significant adverse US tax consequences,” Mr. Yoder wrote, urging US-based multinationals to “enhance their protocols and procedures for monitoring” the transactions.