Debt, Foreign Corporations

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate Stock

Proskauer - Tax Talks on 5/21/2024

On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on...more

Further Measures Adopted by Russia in Response to Sanctions

Dechert LLP on 3/14/2022

Russia continues to introduce restrictive and other measures following the imposition of sanctions by the USA, EU, UK and other countries on Russia....more

The Effect of Tax Reform on Financing Transactions: Thoroughly Review Your Company's Situation

Foley & Lardner LLP on 2/27/2018

In general, the effects of the new tax law should be very favorable to most corporate borrowers. Nevertheless, there may be situations where a corporate borrower benefits economically from a lower tax rate and other favorable...more

Final and Temporary Debt-Equity Regulations Under Section 385 Implement Highly Favorable Changes

BakerHostetler on 10/20/2016

On Oct. 13, 2016, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final and temporary regulations under Section 385 governing the treatment of certain instruments as debt or equity...more

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Latham & Watkins LLP on 4/21/2016

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

Further Crackdown on Offshore Corporations

Lowndes on 9/3/2015

In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships. These regulations provide that debt held by foreign...more

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