Internal Revenue Service June 21, 2016 – Federal Register Recent Federal Regulation Documents

Treatment of a Certain Interests in Corporations as Stock or Indebtedness; Hearing
Document Number: 2016-14734
Type: Proposed Rule
Date: 2016-06-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document provides a notice of public hearing on proposed regulations under section 385 of the Internal Revenue Code that would authorize the Commissioner to treat certain related-party interests in a corporation as indebtedness in part and stock in part for federal tax purposes, and establish threshold documentation requirements that must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for federal tax purposes. The proposed regulations also would treat as stock certain related-party interests that otherwise would be treated as indebtedness for federal tax purposes.