Regulatory Fix for Market Discount Tax Issue Uncertain Despite ‘Mayo'

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A regulatory fix for an issue involving the application of the market discount rules to distressed debt remains uncertain despite broad new regulatory authority given to the Treasury Department under the U.S. Supreme Court's Mayo decision, Treasury Associate Tax Legislative Counsel Michael S. Novey says. Novey says the court's ruling, which found in favor of Treasury, “clarified the standard of review for tax regulations in a way that is very favorable to the government.”