OMA Connections Partner, GBQ, writes that on October 21, 2016, final and temporary regulations under Section 385 were published which address related party financing instruments.
Per GBQ: “The regulations were much-anticipated and contain numerous changes from their original proposed form, addressing comments and concerns raised by practitioners. The initially proposed regulations, released April 4, 2016, were intended to address earnings stripping and the use of cross border debt to reduce U.S. income tax. But, it is important to note that the proposed regulations were not limited to these transactions and could also have an impact on related party debt transactions structured exclusively in the U.S. or solely outside of the U.S.”
And, this will be a topic of discussion when the OMA Tax Committee meets on Wednesday, November 9. Dorothy Coleman, Vice President of Tax and Domestic Economic Policy at the National Association of Manufacturers (NAM) will present. Register here for in-person or phone-in participation. 10/25/2016