Squire Sanders lawyers John W. Hutchinson, Michael A. Cullers and Robert J. Eidnier have recently had an editorial published in Daily Tax Report.
Entitled "Treasury Issues Long-Awaited Issue Price, Other Arbitrage Proposed Regulations: What You Need to Know and a Call to Action," discusses the Treasury Department's long-awaited proposed regulations under the "arbitrage" rules, and explains the pitfalls that this proposal creates. The article also analyzes the other proposed changes under the regulations, which include a new rules that enhances the ability of the Internal Revenue Service to disregard the arbitrage rules to attack perceived arbitrage abuses and generally favorable changes to the rules for grant financings, "qualified hedges" and working capital financings.
©2013 Bloomberg Finance L.P. Originally published by Bloomberg Finance L.P. Reprinted with permission. The opinions expressed are those of the author