On April 4, 2016, the U.S. Treasury Department and the Internal Revenue Service (“IRS”) proposed new regulations that, if finalized, would dramatically change how debt instruments issued between related parties are treated and analyzed (the “Proposed Regulations”). The Proposed Regulations are part of an effort to make so-called “inversion” transactions less attractive to U.S. corporations seeking to combine with a foreign-parented group, and were issued at the same time as other significant regulations specifically addressing inversions. Read more. (Subscription required.)
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