On 11 October 2019, the U.S. IRS published Notice 2019-58, which announces that, following the expiration of the temporary regulations under section 385 on 13 October 2019, taxpayers may rely on the proposed regulations cross-referencing the temporary regulations. --- Notice 2019-58 On October 21, 2016, the Treasury Department and the IRS published T.D. 9790 in the Federal Register (81 FR 72858), which included final and temporary regulations under section 385 addressing documentation in §1.385-2 and certain debt that is issued to a controlling shareholder in a distribution or in another related-party transaction in §1.385-3. On the same date, the Treasury...