CPE was awarded for the live event on April 28, 2016. If you watched the live webcast and qualified for CPE, you may access your certificate by clicking the CPE button at the bottom of the screen.
Live Webcast
Date: April 28, 2016
Time: 12:00 PM EDT
CPE: 1.0
Description:
On April 4, 2016, the IRS and Treasury issued Proposed Regulations under section 385 that, when finalized, would recharacterize many related party loans that are debt under current law as equity. Although the Proposed Regulationsare said to be aimed at curtailing certain types of tax planning, they would be rules of general application that would have a profound impact on routine inter-company lending and treasury operations. Because the Proposed Regulations would apply when finalized to debt issued after April 4, 2016, and because the characterization of such debt under the Proposed Regulations could turn on the payment of dividends after April 4, 2016, taxpayers should give immediate consideration to the potential impact of the Proposed Regulations on current transactions. The Proposed Regulations would also create a contemporaneous documentation requirement for related party debt, applicable to debt issued after the regulations become final. A failure to satisfy the documentation requirement within 30 days of the issuance of a related party debt would result in the debt being characterized as equity.
Join specialists from PwC to better understand how the proposed Section 385 Regulations might impact your business.
Moderator:
- Pam Olson, US Deputy Tax Leader & Washington National Tax Services Leader
Speakers:
- Chip Harter, International Tax Services Principal
- Wade Sutton, Mergers & Acquisitions Principal
- Joel Walters, US Inbound Tax Leader
