The Internal Revenue Service recently expanded its use of debt modification regulations beyond their original scope raising the question, how are the standards in insurance and government bond cases used? Is this recent ‘‘mission creep’’ for the United States Treasury regulations consistent with the rules’ values when promulgated?
While these regulations were originally promulgated to address only the federal income tax consequences to limited changes to debt instruments, in numerous instances as of late, the Internal Revenue Service has used these regulations beyond their original scope.
This webinar is designed to explore the recent “mission creep” of the debt modification regulations and whether such expansion is consistent with the values of such regulations.
- Review the debt modification regulations
- Explore United States Treasury Regulations 1.1001-3
- Analyze “Estate of McKelvey v. Commissioner”
- Address Advice Memorandum 2014-009
Who would benefit most from attending this program?
Legal practitioners, bankers, and companies interested in the legal aspects of debt modification regulations.