Tax Notes Quotes Prof. Hickman On Debt-Equity Pre-Rule

Prof. Hickman was quoted in a Tax Notes article, “Treasury Takes Interim Step on Road to Revising Debt-Equity Regs”, speculating about the significance of a “pre-rule” docketed by the Treasury Department with the Office of Information and Regulatory Affairs (OIRA) regarding the characterization of certain interests in corporations as debt or equity. The article quoted Prof. Hickman regarding Treasury’s past practice of using IRS Notices to signal and solicit public input regarding potential future regulations, and also OIRA review of IRS subregulatory guidance documents more generally.