Debt-Equity Documentation Standards Won’t Apply Broadly


Michael Wilder said that under the new IRS debt-equity rules there are “a lot of tricky issues with expanded group earnings because it’s not earnings and profits; it’s only particular earnings” once the rules take effect. He added that the rules have a strong “anti-importation policy because the government believes it’s important to prevent entities from acquiring earnings accounts from outside the expanded group,” such as when a US group acquires a target from an unrelated party.