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Potential Impacts of Proposed Section 385 Regulations: Inbound and Outbound Examples

On April 4, 2016, the Department of the Treasury and the Internal Revenue Service (“IRS”) issued a Notice of Proposed Rulemaking under Internal Revenue Code section 385.  The Proposed Regulations contain three sets of rules: (1) they authorize the IRS to treat certain related-party debt arrangements as part stock and part debt; (2) they establish a contemporaneous documentation requ irement that must be satisfied for certain related-party debt to be respected as debt; and (3) they treat certain categories of related-party debt as equity, including a rule treating debt issued within a 72-mon

Jobs We Need

When global companies invest in the United States, they bring much more than capital and the jobs it creates.  These employers provide expertise and resources that benefit U.S. workers and local communities across the country.  In fact, it may surprise you to learn that Americans connected to global companies earn higher wages and benefits than the economy-wide average.

2016 CFO Insourcing Survey

Overall, CFO confidence levels in 2016 are similar to 2014, but concerns about the future have risen. The United States is the “top location for growth and new investment” in the next five years for 20 percent of CFOs, up from 13 percent in 2014. However, this looks to be due, in part, to weakening elsewhere. While 33 percent of CFOs chose China as the top destination, its level has fallen from 49 percent in 2014. The percentage of CFOs who expect the U.S.

FDIUS 2016 Report

Foreign direct investment in the United States, known as FDIUS, totaled $2.9 trillion through 2014 on a historical-cost basis. Each year foreign firms make new investments in the United States, which benefit the American economy in numerous ways. They build new factories, grow their well-established U.S. operations, fund research and development, and employ millions of Americans in well-paying jobs.

Coalition Letter to Senate on Pending Tax Treaties

Business Roundtable
Financial Executives International
Information Technology Industry Council
National Association of Manufacturers
National Foreign Trade Council
Organization for International Investment
Software Finance & Tax Executives Council
Trans-Atlantic Business Council
U.S. Chamber of Commerce
United States Council for International Business

January 27, 2016