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Removal of IRS Section 385 Documentation


Understand the factors to take into account when determining debt versus equity.

The classification of an instrument as debt or equity is very important for federal tax purposes. The IRS is authorized to issue regulations providing certain factors that must be taken into account in determining whether a certain instrument is debt or equity (or both). The regulations issued by the IRS, as well as various factors developed by the courts, must be examined when making such a determination. This course will assist those responsible for advising clients on issues regarding debt versus equity, including the documentation requirements or best practices.



Frank Comparetto, III

Frank Comparetto, III

Eversheds Sutherland (US) LLP

  • Associate in the Atlanta office of Eversheds Sutherland
  • Advises multinational clients on domestic and international tax planning and transactional matters, including corporate restructurings, taxable and nontaxable mergers and acquisitions, and related financing
  • Assists clients with complex tax laws and regulations, defending and negotiating for taxpayers in disputes with the Internal Revenue Service and other tax agencies and boards
  • Before joining Eversheds Sutherland, he worked for a Big Four accounting firm, where he focused on domestic and cross-border mergers and acquisitions and advised clients on tax-efficient structuring and tax due diligence
  • Experience includes testing Subchapter S qualifications and counseling corporations on Subpart F income planning, joint ventures, and ownership changes under Code section 382
  • Served as a law clerk for a natural gas and electric company and as an intern for the Thirteenth Judicial Circuit in Hillsborough County, Florida
  • Author of several publications related to his areas of practice
  • LL.M. degree in taxation, University of Florida Levin College of Law; J.D. degree, Board Member, Florida Law Review, University of Florida Levin College of Law; B.A. degree in economics, minor in environmental studies, University of Michigan
  • Can be contacted at [email protected] or 404-853-8031
Margaret R. Pope

Margaret R. Pope

Eversheds Sutherland (US)

  • Associate in the Washington office of Eversheds Sutherland
  • Represents multinational manufacturing, transportation, and commercial corporate clients in connection with the international tax aspects of their cross-border transactions, including mergers and acquisitions, joint ventures, tax credit planning, complex spin-offs, finance company arrangements, and corporate restructurings
  • Offers clients critical analysis concerning Subpart F income planning and advises on currency and hedging transactions in order to align the tax function with clients’ specific business objectives
  • Before joining Eversheds Sutherland, she worked in the international tax group of a Big Four accounting firm
  • Served as a legal intern for the Tax Division Office of Review of the United States Department of Justice and as a legal congressional intern for Congressman Daniel Lungren of the United States House of Representatives
  • Author of several publications related to her areas of practice
  • J.D. degree, cum laude, associate editor, Duquesne Law Review, Duquesne University School of Law; B.S. degree, Miami University
  • Can be contacted at [email protected] or 202-383-0846

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