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New Section 385 Proposed Regulations - Changing the Debt-Equity Landscape

August 02, 2016

  

  • Summary
  • Podcast and Materials
Treasury and the IRS issued proposed regulations under Section 385 that would dramatically impact the debt-equity analysis that currently exists. These proposed regulations provide rules that permit the IRS to bifurcate an instrument into part-debt and part-equity, establish documentation and substantiation requirements in order to have an instrument be treated as debt, and provide rules relating to when a debt instrument will automatically be treated as equity. This webcast will provide an overview of these rules and provide illustrations of situations in which a debt instrument will be treated as equity as well as discussing some of the potential implications when debt is recast as equity.
Access the Podcast

Webinar Handout Materials: New Section 385 Proposed Regulations

Note: CPE credit is not available for the podcast.