United States: New Final Regulations Issued Under Section 163(j) Provide Helpful Clarification - Shearman & Sterling LLP

United States: New Final Regulations Issued Under Section 163(j) Provide Helpful Clarification - Shearman & Sterling LLP

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On January 5, 2021, the Internal Revenue Service (the IRS) and the U.S. Department of the Treasury issued final regulations in T.D. 9943 (the "2021 Final Regulations") under section 163(j)...

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