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China's corporate income tax ( CIT ) regime effective from January 1, 2008 explicitly requires corporate restructuring transactions to be effected at fair value so that any gain or loss shall be recognised for tax purpose at the time when the transaction takes place
On 7 January 2011, the IRS published final regulations intended to clarify when and how a debt instrument should be retested for debt vs. equity status, and when its terms have been significantly modified
