Code Sec. 385: Proposed Debt vs. Equity Regs Would Limit Planning

Overview


Lowell Yoder wrote this bylined article on new proposed regulations to reclassify certain related-party debt as stock. “These regulations would significantly limit the ability of a foreign-based company to leverage its U.S. group and also impede repatriation planning for U.S.-based companies,” Mr. Yoder wrote, adding that numerous comments to the IRS have questioned “the validity, appropriateness and administrability of the regulations.”