Treasury Report Signals Significant Overhauls Coming to Regs

Overview


Michael Wilder said the Treasury Department’s potential relaxation of documentation rules for Section 385 debt-equity transactions shows the Department is “spending the time to revisit the documentation rules and make them more user-friendly and more practical to comply with.” Mr. Wilder added he expects tax reform proposals on inversion transactions to “level the playing field for US parents and multinationals” by making it clear what is permissible.