U.S. Treasury Finalizes Controversial 385 Regulations on Intercompany Debt
Following six months of controversial public debate, on October 13, 2016 the U.S. Treasury Department released final 385 regulations. The new rules will require multinational companies to closely examine their existing intercompany transactions in order to avoid potential recast of related-party financing arrangements.
View the U.S. Treasury’s Press Release, "Treasury Issues Final Earnings Stripping Regulations to Narrowly Target Corporate Transactions That Erode U.S. Tax Base."
To further discuss and prepare for the ramifications of the new regulations, contact Sean King at Align Global Consulting.
About Align Global Consulting
With offices in London, Dublin, Research Triangle Park and Silicon Valley, Align Global Consulting is a globalization consulting and advisory firm that represents clients expanding globally or improving existing operations by providing creative legal and tax solutions to address commercial, trade, investment and regulatory matters. Align's comprehensive list of services includes global structuring, global business transactions, cross-border M&A transactions, and international tax planning for outbound and inbound investment. Align assists companies in all stages of growth, from emerging growth companies to the Fortune 100. With "big firm" credentials and experience, Align handles matters traditionally entrusted to larger firms, while maintaining a commitment to the lost art of one-on-one client service.