United States Government Publishing Office
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FR
Regulatory Information
2016_register
executive
2018-02-07
article
Treatment of Certain Interests in Corporations as Stock or Indebtedness
Part IV
Proposed Rules
D09002ee1bdc1d1be
D09002ee1bdc1d2a6
United States
Department of the Treasury
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org
United States Government Agency or Subagency
United States
Internal Revenue Service
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org
United States Government Agency or Subagency
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.
81 FR 20912
https://www.govinfo.gov/app/details/FR-2016-04-08/2016-07425
2016-07425
fr08ap16-33
RIN 1545-BN40
4830-01-P
REG-108060-15
https://www.govinfo.gov/app/details/FR-2016-04-08/2016-07425
https://www.govinfo.gov/content/pkg/FR-2016-04-08/html/2016-07425.htm
https://www.govinfo.gov/content/pkg/FR-2016-04-08/pdf/2016-07425.pdf
Income Taxes
Reporting and Recordkeeping Requirements
32 p.
20912
20943
81 FR 20912
Code of Federal Regulations
Title 26 Part 1
26 CFR Part 1
Regulation Identification Number 1545-BN40
RIN 1545-BN40
Treatment of Certain Interests in Corporations as Stock or Indebtedness; Federal Register Vol. 81, Issue
PRORULE
2016-07425
IV
DEPARTMENT OF THE TREASURY
Internal Revenue Service
2016-07-07
REG-108060-15
4830-01-P
2016-07425
Notice of proposed rulemaking.
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.
Written or electronic comments and requests for a public hearing must be received by July 7, 2016.
Concerning the proposed regulations under Sec. Sec. 1.385-1 and 1.385-2, Eric D. Brauer, (202) 317-5348; concerning the proposed regulations under Sec. Sec. 1.385-3 and 1.385- 4, Raymond J. Stahl, (202) 317-6938; concerning submissions of comments or requests for a public hearing, Regina Johnson, (202) 317-5177 (not toll-free numbers).
Income Taxes
Reporting and Recordkeeping Requirements
Treatment of Certain Interests in Corporations as Stock or Indebtedness
,
http://www.irs.gov
http://www.regulations.gov
www.regulations.gov
Federal Register
Vol. 81, no. 68
Office of the Federal Register, National Archives and Records Administration
2016-04-08
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708 p.
Table of Contents:
AE 2.7:
GS 4.107:
AE 2.106:
KF70.A2
https://www.govinfo.gov/app/details/FR-2016-04-08
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0042-1219
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https://www.govinfo.gov/app/details/FR-2016-04-08
https://www.govinfo.gov/content/pkg/FR-2016-04-08/pdf/FR-2016-04-08.pdf
https://www.govinfo.gov/content/pkg/FR-2016-04-08/xml/FR-2016-04-08.xml
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2018-02-07
2023-04-29
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FR
FR-2016-04-08
81
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