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Email On October 13, 2016, Treasury and the IRS issued new final and temporary “anti-inversion” regulations under section 385 of the Internal Revenue Code that could treat certain purchasers of notes issued by securitizations as having exchanged their notes for stock in certain related domestic entities. https://www.cadwalader.com/resources/clients-friends-memos/application-of-new-debt-equity-regulations-to-securitizations