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Section 385 debt-equity regulations

Section 385 debt-equity regulations

Final and temporary regulations under section 385, released in October 2016, address the treatment of related-party debt for U.S. tax purposes. The regulations afford significant relief for U.S. multinational groups, and offer some, but less significant, relief for foreign multinational groups. KPMG reports and analyses about the section 385 regulations are collected below.

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Additional information

Read more about the final regulations under section 385 on KPMG's Institutes website

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