Finance & markets · 08/04/2016Updated: 10/17/2026 · 1 min read
Treatment of Certain Interests in Corporations as Stock or Indebtedness
Summary
The proposed regulations under section 385 of the Internal Revenue Code would allow the Commissioner to treat certain related-party interests in a corporation as both indebtedness and stock for federal tax purposes, with specific documentation requirements. This affects corporations that issue debt to related corporations or partnerships.