The Resource Code Sec. 385 proposed regulations would vitiate internal cash management operations

Code Sec. 385 proposed regulations would vitiate internal cash management operations

Label
Code Sec. 385 proposed regulations would vitiate internal cash management operations
Title
Code Sec. 385 proposed regulations would vitiate internal cash management operations
Creator
Subject
Language
  • eng
  • eng
Summary
This article provides brief descriptions of the Proposed Regulations and of common treasury management practices of multinational enterprises. It then focuses on the application of the Proposed Regulations to one of those practices in particular: internal cash management. The broad issues discussed with respect to common practices include (i) how cash management transactions can easily trigger the per se recharacterization rules of the Proposed Regulations; (ii) the consequences of recharacterizing internal funding transactions as equity; and (iii) the extent to which the iterative application of the rules of the Proposed Regulations in the context of a global cash management system likely would recharacterize most cash pool balances as equity. The goal of this article is to identify and describe significant technical interactions between the rules of the Proposed Regulations and the operations of cash pooling and intercompany financing arrangements that would have been extremely difficult for the drafters to have anticipated
Citation source
In: International tax journal. - Chicago. - Vol. 42 (2016), no. 4 (July-August) ; p. 5-14
http://library.link/vocab/creatorName
  • Harter, L.G
  • Hermann, J.A
  • Junge, A.H
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • intercompany loan
  • cash pooling
  • income classification
Label
Code Sec. 385 proposed regulations would vitiate internal cash management operations
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2016/G-I/ITJ/4_5-14.zip
Publication
Note
20161014

Library Locations

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