IRS Makes Changes to Final, Temporary Debt-Equity Regulations
The IRS has made changes to parts of the preamble to the final and temporary debt-equity regulations under Section 385 released in October (see our prior coverage here). Section references are to the Internal Revenue Code of 1986, as amended. The changes are included in paragraphs addressing creditors’ rights, tiered transfers and instruments that are not, in form, debt. The IRS also made correcting amendments to the final and temporary regulations to clarify errors that may prove misleading. The changes are effective on Jan. 23, 2017 and applicable Oct. 21, 2016.

2016 Argentina-U.S. TIEA Available
Treasury has released the text of the Argentina-United States tax information exchange agreement.

Greece-U.S. FATCA Agreement and MOU Available
The text is available of the agreement signed by Greece and the United States to improve international tax compliance and implement the information reporting and withholding tax provisions of FATCA. Additionally, the text is available of the memorandum of understanding that clarifies such agreement.

IRS Revises Audit Technique Guide on Golden Parachute Payments
The IRS has released an updated audit technique guide for examining cases involving golden parachute payments.

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