US Treasury and the IRS released final and temporary Section 385 regulations on October 13, 2016. These regulations address whether certain instruments between related parties are treated as debt or equity.
PwC has created a one-page (11 x 17) summary chart to help you think through these very complex regulations. Note that this summary chart should be your first step in analyzing how the regulations might impact your company. For additional guidance on the Section 385 regulations, please reach out to your regular PwC contact, or one of the contacts listed.
In addition, PwC is hosting a webcast on the Section 385 regulations on Thursday, November 3, at 12:00pm ET. You are welcome to register for this webcast if you have not already.