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On 14 July 2016, the US Treasury Department held its much anticipated hearing on the controversial proposed earnings stripping regulations under Section 385 of the Internal Revenue Code. Taxand USA attended the hearing on behalf of their clients and readers.
In spite of all the legitimate concerns expressed by the more than a dozen speakers at the hearing and in the written comments, there was no indication of any appetite at Treasury or IRS for any major changes or delays in implementation.
The IRS and Treasury attendees expressed no interest in responding to comments or questions raised by the speakers. Even many speakers themselves commented as if these proposed regulations would certainly be finalised and therefore spent their allotted time suggesting modifications.
Given the volume and content of written comments received by Treasury and published prior to the hearing, the hearing itself provided no major surprises. Nonetheless, many of the statements made by speakers revealed some common themes worthy of note.
Discover more: Observations from the proposed earnings stripping regulations hearing
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In terms of immediate actionable reactions, it’s not what has been spoken or written in comments, but rather what was not discussed that matters most. We recommend immediate compliance with at least the first three documentation requirements.