Williams Mullen Mezzanine Lending Video Series - Episode 5
Unlawful Debt Collection Claims - RICO Report Podcast
Advancing Agriculture - Identifying and Addressing Distressed Debts
Pillsbury's Industry Insights - Episode #22: Real Estate Market Update
Path Forward: Borrowing Base Redeterminations In A Restructuring World
THE WONDER YEARS WEBINAR
HEAVEN CAN WAIT
COVID-19 Comeback Plan: Part III - How Banks Think About Loan Defaults: Lessons for Borrowers in Troubled Times
THE WONDER YEARS WEBINAR - LOAN REGIME METHOD OF SPLIT DOLLAR LIFE INSURANCE
THE WAY WE WERE
Williams Mullen's Comeback Plan: Part II - How Banks Think About Loan Defaults: Lessons for Borrowers in Troubled Times
Mad Dogs and Panameños!
It's (Not) Too Late, Baby!
Switch Hitter! Maximizing the Flexibility of Split Dollar Life Insurance to Create Maximum Financial and Tax Leverage
SWITCH HITTER! Maximizing the Flexibility of Split Dollar Life Insurance to Create Maximum Financial and Tax Leverage
FATHER KNOWS BEST
Podcast: Questions & Concerns About Documentation: A Conversation with Colin Adams, M-III Partners
Podcast: Credit Funds: Credit Default Swaps in the Distressed Limelight
The IRS recently concluded that certain commercial property assessed clean energy (“CPACE”) assets are “obligations . . . secured by an interest in real property” under Code Section 860G(a)(3) in a private letter ruling...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 25, 2024 – March 29, 2024....more
On November 24, 2023, the IRS released PLR 202347001, ruling that certificates issued from an “exchange trust” qualify as stripped bonds or stripped coupons within the meaning of Code Section 1286. The taxpayer in the...more
In last month’s 401(k) Compliance Check, we discussed the importance of developing (and maintaining) best practices for handling beneficiary designations. This month, we discuss one of the most common problems faced by 401(k)...more
The IRS Issue Snapshot-Third Party Loans from Plans dated August 23, 2022 is a short advice document for examiners to use when auditing tax-qualified retirement plans that invest in mortgages or other third party loans. IRS...more
To help employers properly administer their 401(k) plans, in 2022, Foley & Lardner LLP is authoring a series of monthly “401(k) Compliance Check” newsletters. This article discusses some of the policies that are important for...more
On March 28, 2022, the US Department of the Treasury released the Fiscal Year (FY) 2023 Revenue Proposals and Green Book, which describes the tax proposals in the Biden administration’s FY 2023 budget (2023 Budget Proposal)....more
Acting to clarify the practical impact of a COVID relief provision enacted earlier this year, the IRS has announced in Notice 2022-1 (Notice) that lenders are not required to, and should not, issue Forms 1099-C when certain...more
Loans under the Payroll Protection Program (PPP) are eligible for forgiveness depending upon whether and when the loan proceeds are used for qualified business expenses. One of the benefits of this program is that there is no...more
The Paycheck Protection Program money is spent, the temporary $600 weekly unemployment supplement is over, and we still need money. We could draw on our savings, sell investments, or take out a loan against our home. Usually,...more
Hedge Fund managers previously had an unprecedented ability to defer their carried interest in the offshore hedge funds that they manage. IRC Sec. 409A put an end to those deferrals and required hedge fund managers to...more
Because of the current pandemic, the August 2020 applicable federal rates and section 7520 rate are at historical lows, creating opportunities for interest sensitive estate and gift tax planning. Loans to family members or...more
In Bordelon v. Commissioner, the Tax Court addressed the circumstances under which an individual’s personal guarantee of a loan to his single-member LLC established sufficient amounts at risk to enable him to claim more than...more
The IRS has issued eagerly anticipated pre-guidance clarifying certain aspects of the CARES Act’s withdrawal and loan relief provision applicable to retirement plans (the “New FAQs”). This article expands on our prior...more
The Taxpayer First Act (the “Act” or “TFA”) imposes new limits on the disclosure of US taxpayer tax information obtained on or after December 28, 2019. The Act is designed, among other things, to overhaul and modernize...more
The Taxpayer First Act adopted in the summer of 2019 includes the following provision that has an effective date of December 28, 2019...more
• The recent Tax Cuts and Jobs Act of 2017 (the Act), enacted on Dec. 22, 2017, contains a few rules that will impact benefit administrators. • This client alert focuses on changes made to the tax treatment of plan loan...more
A recent tax court case, Louelia Salomon Frias, v. Commissioner, TC Memo 2017-139, illustrates why it is good practice to verify that employee loan repayments have been timely deducted. Plan Loan Requirements. An employer...more
Following Hurricane Harvey and its resulting destruction, many employees are in need of financial assistance and/or early access to retirement funds. We will highlight how employers can make direct financial assistance...more
Two recent legislative developments, which have largely gone unnoticed, will dramatically raise the stakes for mortgage servicers and originators who file IRS Forms 1098. First, the Trade Preferences Extension Act of 2015,...more
Recently, and shortly after my visit to several lender clients to make presentations regarding, among other topics, the enforceability of commercial guaranty agreements and the sham guaranty defense, the California Court of...more