Recharacterizing Debt as Equity - How the Proposed Section 385 Regulations Will Impact Traditional Cross-Border Income and Estate Tax Planning

Anthony De Yurre moderated a panel of U.S.-focused developers and operators on the "Direct Investment Panel (U.S. Focus)" at The Latin America U.S. Real Estate Meeting.

Depending on the type of investment, income from private equity funds to foreign investors will be treated differently for tax purposes. In some cases, hefty withholding requirements can come into play, shaving off a significant chunk from return-on-investment.It is therefore important to understand...