Stefanie Perrella and Zachary Held Published in Tax Notes: Retaining Advantages of Intercompany Debt Financing for Private Equity Funds

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Amidst the current regulatory uncertainty, all indications suggest that as long as interest deductibility remains part of the U.S. tax code or creates an inherent conflict of interest for related parties, regulators will continue to focus on debt characterization. Thus, it is important for private equity ("PE") firms to navigate the current and ever-changing regulatory environment and be advised of steps they can take to prudently minimize regulatory risks while retaining the benefits of optimized tax structures.

In Tax Notes' weekly publication, Stefanie Perrella, a director, and Zachary Held, a vice president, in Duff & Phelps' transfer pricing practice, discuss the challenges that regulations create for PE firms that use intercompany debt to finance investment vehicles, and offer recommendations for compliance.

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