The Internal Revenue Service and the Treasury submitted final and temporary regulations to the Office of the Federal Register regarding requirements related to equity-linked instruments.
The IRS and the U.S. Treasury Department examined proposed regulations to the Internal Revenue Code that would recharacterize certain debt instruments issued to related parties as equity for U.S. federal income tax purposes.
The Internal Revenue Service and the Treasury will hold a public hearing to review jointly proposed debt-equity regulations. The proposed regulations were published in the Federal Register.
A hotel and resort company delayed the planned acquisition of a vacation ownership business as a result of new understandings of the tax consequences of the deal under the Foreign Investment in Real Property Tax Act.
The Senate Finance Committee announced it will hold a hearing on July 22, 2014 to discuss corporate inversions as well as other international tax issues. According to a letter written by Secretary of the Treasury Jacob Lew to the the House Committee on Ways and Means, there have been recent reports of a number of corporate inversion transactions "designed to change the tax domicile of a U.S.-based multinational firm" involving the purchase of a foreign corporation, the transfer of tax domicile to the foreign firm's country of incorporation, and the shifting of tax liability for the combined