Proposed Regs: Transactions Involving Disregarded ENtities Considered in Financing Arrangement Determinations

REG-113462-08 contains proposed regulations relating to conduit financing arrangements issued under the authority granted by IRC Sec. 7701(l).  The proposed regs apply to multiple-party financing arrangements that are effected through disregarded entities, and are necessary in order to determine which of those arrangements should be recharacterized under IRC Sec. 7701(l) and Treas. Reg. §1.881-3. 

Written or electronic comments and requests for a public hearing must be received by March 23, 2009.

Posted by Lewis J. Saret, General Editor, Wealth Strategies Journal.