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Perspectives
US Inbound Corner
Navigating complexity
US Inbound Corner is a bulletin of the latest tax developments affecting businesses investing into the United States. Written by professionals of the Deloitte member firms, the newsletter provides invaluable insights on a broad range of topics affecting US inbound taxpayers.
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June 2024
In this edition,
The continued relevance of section 385 recast rules and impact for multinationals
As interest rates and inflation continue to climb, an increasing number of non-US parented groups need to adjust their financing profile to either account for more intercompany debt at their US subsidiaries or pull cash out of their US subsidiaries.
Before implementing any such change, we recommend analyzing such change under Treas. Reg. § 1.385-3 to ensure that it doesn’t inadvertently cause a new or existing loan to be recharacterized as equity.
Learn: Rules under Treas. Reg. § 1.385-3 whereby a debt instrument can be recharacterized as equity & what it means for MNCs.
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June 2024
