When Will Deemed Dividends Under Section 305(c) Become a Final Rule? Or Has it Already?

In April of 2016, the IRS published proposed regulations providing that conversion rate adjustments (CRAs) on convertible instruments are deemed dividends and are subject to withholding by withholding agents.  A comment period was scheduled ending 7/12/2016 in which seven comment letters were filed and posted to the docket on Regulations.gov.  On 7/5/2016, the IRS published […]