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Section 385 Regulations - is your business prepared?

USA
22 Jul 2016

On April 4, 2016, the IRS and Treasury released two sets of proposed and temporary regulations that caused various taxpayers, investment bankers and large sectors of the investment community, particularly in the pharmaceutical and biomed sectors, to sound alarm bells.

Since then, On 14 July 2016, the US Treasury Department held its much anticipated hearing on the controversial proposed earnings stripping regulations. In spite of all the legitimate concerns expressed by the more than a dozen speakers at the hearing and in the written comments, there was no indication of any appetite at Treasury or IRS for any major changes or delays in implementation.

It would appear the Treasury is determined to go ahead with these new regulations. Taxand USA will keep you updated with all the developments in this area.

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Jill Harding
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E. jmharding@alvarezandmarsal.com

Albert W. Liguori
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E. aliguori@alvarezandmarsal.com

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