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Orrick attorneys authored an article, titled "Proposed Regulations Under §385 Classifying Interests in a Corporation," addressing Section 385 regulations proposed by the Internal Revenue Service and the U.S. Treasury Department...
Orrick attorneys authored an article, titled "Proposed
Regulations Under §385 Classifying Interests in a
Corporation," addressing Section 385 regulations proposed by
the Internal Revenue Service and the U.S. Treasury Department to
address the excessive use of debt to reduce the U.S. tax base. The
article was published in the Tax Management International
Journal and is available here.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.