Final and Temporary Section 385 Regulations

On October 13, the IRS and the Treasury Department released final and temporary regulations under section 385 relating to the classification of certain intercompany loans as debt or equity for U.S. federal income tax purposes. The basic structure of the regulations remain unchanged, however, there are a number of significant changes to the proposed regulations that were released in April.

Please join Davis Polk for a discussion of the recent IRS and Treasury regulations. Topics will include:

• Analysis of the new intercompany debt regulations
• Significant changes and additional exceptions
• Live Q&A

Final and Temporary Section 385 Regulations » Our recent memorandum summarizing certain of the most important aspects of the regulations.