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Expansive Debt/Equity Regulations Finalized with Modifications from Proposed Regulations

USA - November 21 2016 On April 4, 2016, Treasury released proposed regulations under Section 385 of the Internal Revenue Code ("Code") governing when intercompany debt will…

Jeffrey A. Goldman, Robert W. Nelson

IRS Plans to Increase Taxes on Family Businesses through New Valuation Rules

USA - August 11 2016 On August 2, 2016, the United States Treasury Department (the “Treasury Department”) released proposed regulations under Section 2704 of the Internal…

Laura M. Callahan, Michael G. Cumming, Marie R. Deveney, Anthony J. Frasca, Robert W. Nelson

Update Regarding Department of Treasury Proposed Section 385 Regulations on Classification of Instruments as Debt or Equity

USA - June 6 2016 As an update to Dykema's May 2 alert entitled, Implications of Proposed Debt/Equity Regulations Extend Far Beyond Anti-Inversion Measures…

James Brandell, Jeffrey A. Goldman, Mary Beth L. McGowan, Robert W. Nelson

Implications of Proposed Debt/Equity Regulations Extend Far Beyond Anti-Inversion Measures

USA - May 2 2016 On April 4, 2016, Treasury released proposed regulations under Section 385 of the Internal Revenue Code (“Code”) governing when intercompany debt…

Jeffrey A. Goldman, Robert W. Nelson

Private Equity Funds Unexpectedly Liable for Pension Liabilities of Portfolio Company; Possible Impact on Fund Income Tax Positions

USA - April 27 2016 A March 28, 2016, decision by the U.S. District Court for the District of Massachusetts in Sun Capital Partners III, LP v. New England Teamsters &…

Jeffrey A. Goldman