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Final Related-Party Debt Regulations Provide Exceptions for Insurance Industry
24 October 2016
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The Treasury and the IRS have issued final and temporary regulations addressing the treatment of certain debt instruments issued between related parties as stock for U.S. federal income tax purposes.
The regulations include welcome guidance for the insurance industry, including a general exception for regulated insurance companies from the equity recharacterization rules and an exception that permits surplus notes to satisfy the requirements of the documentation rules.
Gary M. Friedman
Peter A. Furci
Peter F.G. Schuur
Adam M. Namm
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