21 September 2018 BREAKING TAX NEWS | Treasury issues proposed regulations to remove the final Section 385 regulations establishing minimum documentation requirements for indebtedness The US Treasury Department has issued proposed regulations (REG-130244-17) to remove the final Section 385 regulations that set forth minimum documentation requirements that must be satisfied for certain related-party interests in a corporation to be treated as indebtedness for federal tax purposes. The preamble to the proposed regulations indicates Treasury is continuing to study the issues addressed by the documentation requirements and may propose a modified version of the documentation requirements in the future. The preamble further states that any new regulations would be simplified and streamlined to reduce the burden on US corporations, but they would require sufficient documentation for tax administration purposes. A Tax Alert is forthcoming. Document ID: 2018-9022 |
