Space at night


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.​

Subscribe and archives

Subscribe to receive US Inbound Corner via email.

Recent editions appear below; for older issues, please email a request to

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.

Download to learn more.

Unlock US Inbound Tax insights. Subscribe to stay informed.

June 2024
Did you find this useful?