The U.S. IRS and Treasury have issued the final regulations on the Treatment of Certain Interests in Corporations as Stock or Indebtedness (TD 9897), which was published in the Federal Register on 14 May 2020. The regulations finalize the 2016 Proposed Regulations without any substantive change. In addition, the related Temporary Regulations, which expired on 13 October 2019, are withdrawn.
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SUMMARY:
This document contains final regulations regarding the treatment of certain interests…