Down-market Implications of the Proposed §385 Regulation
from Premier International Tax Library via Bloomberg BNA
The initial offering from one of the most important regulations projects of the last 35 years has the potential to significantly affect more than related-party transactions involving public companies and large privately held enterprises. The documentation requirements of Prop. Reg. §1.385-2 would apply to public companies or groups of privately owned companies with total assets exceeding $100 million or annual total revenues in excess of $50 million.
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