Tax Alerts

Changes to US related-party debt regulations

Marilyn Hayre Marilyn Hayre

On October 13, the US Treasury Department and the IRS released new final and temporary Section 385 regulations (TD 9790) addressing the treatment of related-party debt. The regulations, initially proposed in April, were seen in some quarters as controversial in the way they limit previously commonplace business transactions that involve related parties—for example, cash pooling—as well as common treasury management techniques.

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