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U.S. House and Senate Republicans Continue to Urge Revisions to Proposed Debt-Equity Regulations

24 August 2016

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Proposed Changes

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United States

In the latest effort to urge Treasury to revise proposed debt-equity regulations, Republicans from the U.S. House of Representatives and the Senate sent two letters to Treasury Secretary Jacob Lew on 22 August 2016. The proposed regulations (REG-108060-15) are under Internal Revenue Code section 385, and are mainly intended to counter corporate inversions and earnings stripping by allowing the IRS to recharacterize certain related-party interests as equity or part debt / part equity. The House letter was sent by House Ways and Means Committee Chairman Kevin Brady R-TX, Tax Policy Subcommittee Chairman Charles Boustany R-LA, and all other Committee Republican...