Firm Targets Treatment of E&P Distributions Under Debt-Equity Regs

Overview


Lowell Yoder and Damon Lyon gave written comments to the IRS regarding proposed debt-equity regulations. The lawyers addressed the treatment of distributions from earnings and profits that have already been taxed under section 951(a), asking for a broadening of the current year E&P exception or a stand-alone exception to let taxpayers distribute previously taxed income without implicating the general or funding rules.