The business community is beginning to recognize that Treasury’s new Section 385 regulations published on April 4th have a much broader reach than anybody thought. S corporations in particular need to pay attention.
How broad are they? Here’s how Tax Notes described a meeting of the ABA Section of Taxation here in DC last week:
Practitioners who specialize in the taxation of S corporations said they’re concerned that many S corps may end up gratuitously losing their S corp status if the new related-party debt rules are applied as written without exception.
Thomas J. Nichols of Meissner Tierney Fisher & Nichols SC said that …