The U.S. IRS has issued IRS Notice 2017-36, which announces and invites comments on a change to be made to the timing of application of certain portions of the final and temporary regulations (T.D. 9790) under section 385 that relate to the documentation necessary to determine whether an interest in a corporation is treated as stock or indebtedness for all purposes of the Code (Documentation Regulations). The final and temporary regulations, which are meant to address corporate inversions an…