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Daily Tax Report Quotes Charles Ruchelman on Pending Separation of Powers Act and Its Impact on Proposed Debt-Equity Regulations

July 25, 2016, Daily Tax Report

Daily Tax Report spoke with Charles M. Ruchelman on a bill that moved through the House and is now heading to the Senate which could eliminate debt-equity regulations for multinational corporations. For the full article, please visit the Daily Tax Report's website (subscription required).

Excerpts taken from the article.

If the bill were to pass, regulations such as Treasury's debt-equity proposal would get a higher level of scrutiny if they further the intent of tax code Section 385, Charles Ruchelman, a member at Caplin & Drysdale, Chartered, told Bloomberg BNA.

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Casino-Like Odds

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The legislation would mean that agencies, including the Internal Revenue Service, would have “less flexibility in dealing with problems,” Ruchelman said. “They would have to make sure that a regulation is consistent with legislative intent unless there is a direct grant of authority, and even in those cases there would be less deference shown and agency would be required to demonstrate a link between the action they took and the statute.”


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