1-Hour Program

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Overview

On April 4, 2016, the Internal Revenue Service (IRS) and the Treasury Department issued Temporary Regulations under Section 7874 of the Code implementing Notice 2014-52 and Notice 2015-79, to address certain transactions structured to avoid the purposes of section 7874 and certain post-inversion transactions.  On the same day, the IRS and the Treasury Department issued Proposed Regulations under section 385 of the code to treat certain related party debt instruments as stock. 

In this One-Hour Briefing, Joshua D. Odintz, partner at Baker & McKenzie LLP and Eric B. Sensenbrenner, partner at Skadden, Arps, Slate, Meagher & Flom LLP will discuss this recent guidance with Brenda L. Zent, Special Advisor, Office of the International Tax Council, U.S. Department of the Treasury, John J. Merrick, Senior Level Counsel to Associate Chief Counsel (International), Internal Revenue Service and Raymond J. Stahl, Assistant to the Branch Chief, Associate Chief Counsel (International, Branch 5), Internal Revenue Service. The program will focus on: 

  • New Provisions contained in Temporary Regulations under section 7874
  • Proposed Regulations under section 385
  • Potential impact of the recent guidance

Credit Details