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§385 Regulations Adopted with Helpful Changes, but Significant Impact Remains

Volume 3 No 10    /    Read Article

By Philip R. Hirschfeld

On October 13, 2016, the Treasury Department released final and temporary regulations under Code §385 relating to the tax classification of debt. The new rules were proposed initially in April and were followed by a torrent of comments from Congress, business organizations, and professional groups. In the final portion of his trilogy on debt-equity regulations, Philip R. Hirschfeld explains the helpful provisions that appear in the final regulations and cautions that not all controversial proposals were modified.    See more →