United States - New Rules Proposed for Debt-Equity Classification
- United States
- P. Carman
- Derivatives & Financial Instruments, 2016 (Volume 18), No 3
- 11 July 2016
In April 2016, the US Treasury proposed new Regulations under section 385 of the Internal Revenue Code that are intended to govern the classification of instruments between related entities as debt or equity in a variety of circumstances. The author discusses the two aspects of the proposed Regulations that represent a significant change in direction compared to traditional US authorities on debt-equity classification.