IRS issues final anti-conduit regulations on the treatment of disregarded entities

December 2011

Overview

Today the IRS and Treasury Department issued final regulations relating to multiple-party financing arrangements that are effected through disregarded entities. These regulations, which finalize regulations issued in proposed form on December 22, 2008, treat an entity disregarded as separate from its owner as a separate person for purposes of determining whether a conduit financing arrangement exists.

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