Final and Temporary Section 385 Regulations

Final and Temporary Section 385 Regulations

Global Tax Webcast

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Final and Temporary Section 385 Regulations: Refined to focus on foreign multinationals and limit application to US multinationals

The Treasury Department and IRS have released final and temporary regulations under section 385, addressing the treatment of certain related-party corporate interests as debt or equity for U.S. federal income tax purposes. In the six months between proposal and finalization, the policy and execution of the regulations were roundly criticized by commenters. Treasury and the IRS have responded by making meaningful and welcome changes in the new rules. The operative provisions nevertheless introduce new compliance burdens and changes in the treatment of related-party debt.

KPMG International is pleased to invite you to a one-hour Webcast on the new section 385 regulations. Professionals from KPMG’s member firms will review the regulations, highlight changes from the proposed version, and discuss the consequences for corporate taxpayers, covering:

  • Significant changes in the scope of the regulations and new exceptions
  • Effective dates, applicability dates, and transition
  • Documentation requirements
  • Recharacterization rules
  • Treatment of U.S. consolidated groups

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