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New US tax rules on Related Party Debt

15 April 2016

Summary of proposed regulations issued by the IRS and Treasury under section 385 of the Internal Revenue Code that treat related party debt as stock. These overturn case law and tax practice. The new rules also impose strict contemporaneous documentation requirements for related party debt and provide that, on audit, the IRS may treat a debt instrument as part debt and part equity.

Read the full article: New US tax rules on Related Party Debt

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