Tax Talk: Volume 9, Issue 1

Editor's Note

Things are getting crazy. No, we don't mean what's going on in the U.S. presidential campaign (although we do update you on the remaining candidates' tax positions in this issue of Tax Talk), but what's happening on the administrative law side of the tax house. In Q1, the IRS continued its ramped up rulemaking with regulations on broker reporting on debt instruments and OID on tax-exempt bonds, nonrecognition transfers of loss property to corporations, and partnership allocations of creditable foreign tax expenditures.¹ Shortly after the quarter ended, surprise regulations under Section 385² were issued as part of anti "inversion" guidance. As we reported in our Client Alert,³ these regulations have potential to affect transactions far beyond inversions, however. Counterbalancing that IRS activity is a serious upswing in talk about challenging regulations.⁴ While this issue has always been around, last summer's decision in Altera⁵ stoked the