The U.S. IRS and Treasury have issued final regulations TD 9880. TD 9880 removes § 1.385-2, which established minimum documentation requirements that ordinarily must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for Federal tax purposes. The documentation requirements were introduced as part of debt-equity regulations under section 385 to address corporate inversions and earnings stripping, which were published 21 October 2016. The documentation requirement was initially extended to 1 January 2018 and subsequently extended to 1 January 2019 ({News-2018-08-03/A/7-previous coverage}). A notice of proposed regulations (REG-130244-17) to remove the documentation requirements was...