federal_register: 2016-07425

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2016-07425 Treatment of Certain Interests in Corporations as Stock or Indebtedness Proposed Rule This document contains proposed regulations under section 385 of the Internal Revenue Code (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. The proposed regulations generally affect corporations that issue purported indebtedness to related corporations or partnerships. 2016-04-08 2016 4 https://www.federalregister.gov/documents/2016/04/08/2016-07425/treatment-of-certain-interests-in-corporations-as-stock-or-indebtedness https://www.govinfo.gov/content/pkg/FR-2016-04-08/pdf/2016-07425.pdf Treasury Department; Internal Revenue Service 497,254 This document contains proposed regulations under section 385 of the Internal Revenue Code (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...  

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