Debt Dialogue: November 2016

This month's issue of Debt Dialogue address developments in areas of debt, taxation, settlement cycles for securities and bank debt and securities law enforcement for muni debt. We also share some thoughts on various indenture-related issues.

Topics covered in this issue include:

• U.S. Treasury Finalizes Regulations Recharacterizing Certain Debt Between Related Parties as Equity
  On October 13, 2016, the Treasury Department finalized highly controversial regulations under Section 385 of the Internal Revenue Code that recharacterize certain debt between related parties as equity for federal income tax purposes. The final regulations retain the same basic architecture as when they were proposed in April, but add several exceptions that significantly scale back their scope, at the cost of increased complexity.