DONALD TRUMP, SECTION 385, AND CONSOLIDATED GROUPS

[...]in several prominent tax reform plans (e.g., the House Republicans' tax reform "blueprint"), corporate interest payments would no longer be deductible.3 In any world in which interest is not deductible for U.S. tax purposes, the Section 385 regulations would be a pointless exerci...

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Bibliographic Details
Published in:Corporate Taxation 2017-01, Vol.44 (1), p.33
Main Author: Sutton, Wade
Format: Article
Language:English
Subjects:
Consolidated tax returns
Debt
Equity
Internal Revenue Code
Preferred stock
Tax deductions
Tax reform
Trump, Donald J
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Summary:[...]in several prominent tax reform plans (e.g., the House Republicans' tax reform "blueprint"), corporate interest payments would no longer be deductible.3 In any world in which interest is not deductible for U.S. tax purposes, the Section 385 regulations would be a pointless exercise in regulatory complexity serving no articulable tax policy goal.4 If that is indeed the case, the entire summer of controversy and speculation over the Section 385 regulations would have been a spectacular waste of intellectual effort.5 So, an informed reader with limited time and attention span might wonder: "should I even bother learning these rules?" Or, more directly, "why, Wade, should I read this column?" Fair question. [...]if the regulations remain in effect, many companies will need to have taken proactive measures to avoid an adverse impact.
ISSN:1534-715X