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11 October 2019

BREAKING TAX NEWS | Debt-equity recharacterization regulations remain in place for now

In Notice 2019-58, the IRS announced that taxpayers may continue relying on the October 2016 proposed regulations under IRC Section 385 on characterizing certain corporate interests as stock or debt, even though the temporary regulations expire on October 13, 2019. The expiration of a significant portion of the overall regulatory framework is expected to raise numerous questions regarding ongoing taxpayer compliance with the regulations that remain in place. A Tax Alert on the Notice is forthcoming.

Document ID: 2019-9022

 

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