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U.S. GAO Finds New Debt-Equity Regs in Compliance with Promulgation Rules

01 December 2016

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Approved Changes

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United States

On 28 November 2016, the U.S. Government Accountability Office (GAO) released its report on the compliance of the IRS's promulgation of new debt-equity rules to address corporate inversions and earnings stripping. The rules were published in the Federal Register as final and temporary regulations entitled "Treatment of Certain Interests in Corporations as Stock or Indebtedness" on 21 October 2016 ({News-2016-10-14/A/2- previous coverage}). The rules, which were strongly opposed by trade groups and lawmakers on both sides of the aisle, establish threshold documentation requirements that ordinarily must be satisfied in order for certain related-party interests in a corporation to be treated...