Publications Memos Go Back Qualified Reopening of Debt Issuances 11.09.99 This memorandum discusses proposed regulations issued by the Treasury on November 5, 1999 that provide guidance on an issuer’s ability to reopen prior debt issuances and issue additional securities. Related Insights 01.20.26 | Publications Fifth Circuit Rules That Soroban Was Incorrectly Decided and SECA Tax Exception Applies to Limited Partners With Limited Liability Regardless of Activities 12.15.25 | Publications IRS Releases Final and Proposed Regulations Under Section 892 10.21.25 | Publications IRS Releases Proposed Regulations Under Section 897 on Domestically Controlled REITs Related Services Related Practice Areas Tax