On 11 October 2019, the U.S. IRS published Notice 2019-58, which announces that, following the expiration of the temporary regulations under section 385 on 13 October 2019, taxpayers may rely on the proposed regulations cross-referencing the temporary regulations.
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Notice 2019-58
On October 21, 2016, the Treasury Department and the IRS published T.D. 9790 in the Federal Register (81 FR 72858), which included final and temporary regulations under section 385 addressing documentation…