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Beyond Labels: Exploring the Revised Scope

Beyond Labels: Exploring the Revised Scope of the Final & Temporary §385 Debt-Equity Recharacterization Regulations (On-Demand Program)

Wednesday, November 2, 2016 | 6-8:30 pm CLE credit: NY: 2.5 pp CA: 2.0 general NJ: 2.5 general PA: 2.0 general On-Demand Program: $119 Member | $219 Nonmember Download Program Agenda & Faculty. Download Registration Form

On April 4, 2016, the IRS issued proposed regulations under Code §385 that far exceeded the scope of the revised inversion rules that the business and tax community had anticipated. Following significant public and Congressional scrutiny and debate, on October 13, 2016, Treasury released more narrowly tailored Final & Temporary regulations that contain a number of exceptions that were presumably designed to respond to the numerous public comments that were filed with the IRS. The Taxation of Business Entities Committee of the New York City Bar Association invites you to join us, renown tax policy speakers Lee Sheppard & Prof. Daniel Shaviro, practice area specialists, and industry representatives for a CLE event that will explore the basic structure of the Final & Temporary regulations, the ways in which the Final & Temporary regulations differ from the broader regulations that were initially proposed, the practical implications of the new rules from an industry perspective, and some of the relevant administrative law and tax policy implications.




Where
New York City Bar 42 West 44th St New York, NY 10036

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