A mixed bag for sovereign wealth and pension funds.
The good news regarding the final Section 385 rules is that they are significantly less burdensome than the proposed Section 385 rules. However, this does not mean that taxpayers, including pension funds and sovereign wealth funds (SWFs), have cause to celebrate.
The final Section 385 rules are long and complicated, and companies are still trying to digest their full impact. But some things are for certain: they appear to be here to stay and actions should be taken now.
For background, highlights of Section 385, details on the recast rules and the documentation rules, and eight steps to take now click here.