U.S. Proposed Regulations on Treatment of Certain Interests in Corporations as Stock or Indebtedness
The U.S. IRS and Treasury have issued proposed regulations (REG-123112-19) on the treatment of certain interests in corporations as stock or indebtedness, which were published in the Federal Register on 4 November 2019. The proposed regulations would amend the Distribution Regulations under Section 385, which provide that the issuance of a debt instrument by a member of an expanded group to ano…
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