SALT Implications of Final Section 385 Debt-Equity Regulations - McDermott Will & Emery

SALT Implications of Final Section 385 Debt-Equity Regulations

Overview


Peter Faber wrote this bylined article discussing the final Treasury regulations under Internal Revenue Code section 385. “The final regulations significantly narrow the scope of the proposed regulations in many respects,” Mr. Faber wrote. “Still, they are sweeping and are likely to have many unintended consequences, particularly in the SALT area.”