Significant 2016 Federal Changes to the Debt-Equity Rules and Partnership Audits: Implications for State Taxation

In their efforts to regulate international corporate inversion transactions, Treasury and the IRS have proposed regulations under Section 385 of the IRC that could significantly increase the recharacterization of debt as equity. Congress has also enacted legislation that dramatically alters how large partnerships are taxed and audited. The breadth of these proposed changes has shocked taxpayers and tax practitioners alike. This panel will explore the federal tax changes and discuss the options for states in conforming (or not) to the proposed new rules.

Other Speakers:

Michael Carchia, Capital One Services
Barbara Coulter, PricewaterhouseCoopers LLP