EYUS Treasury and IRS finalize DRD anti-abuse regulations with few changes
|Tax Alerts, National/Federal Taxation, L ...|United States
Executive summary
On 21 August 2020, the United States (US) Treasury Department (Treasury) and the Internal Revenue Service (IRS) released final regulations under Internal Revenue Code1 Section 245A (TD 9909) providing anti-abuse rules for “extraordinary dispositions” and “extraordinary reductions.” These regulations finalize proposed regulations and replace temporary regulations that were issued in June 2019. (For discussion of the proposed and temporary regulations, see EY Global Tax …