Final and Temporary Section 385 Regulations: Global tax | KPMG | UK

US Final and Temporary Section 385 Regulations: Global tax webcast

US Final and Temporary Section 385 Regulations

The webcast will review the regulations, highlight changes from the proposed version, and discuss the consequences for non-US headquartered taxpayers.

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Partner and Head of International Tax

KPMG in the UK

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The US Treasury Department and Internal Revenue Service (IRS) have released final and temporary regulations under section 385, addressing the treatment of certain related-party corporate interests as debt or equity for US federal income tax purposes. In the six months between proposal and finalisation, the policy and execution of the regulations were criticised by commenters, and the Treasury and the IRS have responded by making meaningful and welcome changes in the new rules. The operative provisions nevertheless introduce new compliance requirements and changes in the treatment of related-party debt. In particular, they place significant new restrictions on the use of related party debt of US subsidiaries. KPMG International will be hosting a webcast on the new section 385 regulations on 30 November.

Professionals from KPMG member firms will review the regulations, highlight changes from the proposed version, and discuss the consequences for non-US headquartered taxpayers, covering:

  • Significant changes in the scope of the regulations and new exceptions;
  • Debt recharacterisation rules;
  • Documentation requirements;
  • Effective dates, applicability dates and transition; and
  • The treatment of US consolidated groups.

The webinar will take place at 2pm on Wednesday 30 November 2016. You can register now.

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