In a letter dated 1 July 2016, seven U.S. Senators from the Senate Finance Committee urge Treasury Secretary Jacob Lew to delay the proposed debt-equity regulations under Internal Revenue Code section 385 (REG-108060-15). The regulations 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 regulations also include documentation and financial analysis requirements for debt instruments to be treated as indebtedness for federal tax purposes when issued to a related party. In the letter, the Senators list a number of issues to...