Internal Revenue Service September 24, 2018 – Federal Register Recent Federal Regulation Documents

Proposed Removal of Section 385 Documentation Regulations
Document Number: 2018-20652
Type: Proposed Rule
Date: 2018-09-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document proposes removing final regulations setting forth minimum documentation requirements that ordinarily must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for federal tax purposes (Documentation Regulations). This notice of proposed rulemaking also proposes conforming amendments to other final regulations to reflect the proposed removal of the Documentation Regulations. The final regulations to be amended and removed generally affect corporations that issue purported indebtedness to related corporations or partnerships.