Regulations on inversions and on debt-equity | KPMG | GLOBAL

KPMG reports: Initial analyses of regulations on inversions and on debt-equity

Regulations on inversions and on debt-equity

The Treasury Department and IRS on April 4, 2016, released final and temporary regulations addressing certain “inversions”—the generic term for a domestic corporation’s adoption of a foreign-parented corporate structure—and certain post-inversion restructuring transactions. At the same time, the Treasury and IRS released proposed regulations under section 385 regarding the treatment of certain related-party corporate interests as debt or equity for U.S. federal income tax purposes.


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Also on April 4, the Treasury and the White House released an updated framework for business tax reform that includes updated data regarding the need for tax reform and highlights key elements of the president’s tax reform proposals.


Read two April 2016 printable reports prepared by KPMG LLP: 


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