The U.S. IRS and Treasury have issued final regulations TD 9880. TD 9880 removes § 1.385-2, which established minimum documentation requirements that ordinarily must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for Federal tax purposes. The documentation requirements were introduced as part of debt-equity regulations under section 385 to address corporate inversions and earnings stripping, which were published 21 October 2016. The d…