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
On April 24, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued final regulations on the definition of “domestically controlled” real estate investment trusts (“REITs”)...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
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more
Heads I Win, . . . - When closely held corporations that are under common control engage in any intercompany transaction, it is prudent for the corporations and their shareholders to ensure that the transaction is being...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
What Was Intended? Transactions between commonly controlled, closely held businesses are often conducted in an informal manner. This is unfortunate because, in the absence of documentation, it is sometimes difficult to...more
Third-Party Payroll Providers Cleared - On June 13, 2023, the U.S. Small Business Administration (“SBA”) issued new FAQ 72 (“FAQ 72”) to help clarify whether amounts paid by borrowers to third-party payers for the...more
Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more
Last Friday, December 30, 2022, during the final hours of the 117th Session of Congress, the House Ways and Means Committee – through which all tax legislation passes – released redacted versions of six years of Mr. Trump’s...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
When is a loan not a loan? When it’s something else – for example, equity. This is one of those pesky facts and circumstances issues that plague courts, taxpayers, and tax advisers to no end. Debt- On one end of the...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
LIBOR Relief Included In Appropriations Bill - New York Law Concerns - The New York law enacted in April 2021 provides the ‘Get Out of Jail’ card[2] for banks from litigation relating to the LIBOR (London InterBank...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
Uses of Cryptocurrency Overview- As previously detailed, there are a number of regulations surrounding Cryptocurrencies which vary by location (State Regulations) and by federal agency (FINCEN Regulations, IRS Regulations,...more
When interest rates are low, intrafamily loans can be a good way to assist a relative (typically a child) with purchasing a house or a family business, and in certain circumstances they can be used to gift money to the next...more
The Dog Days- I’ve never much cared for the month of August. In New York, at least for me, the eighth month of the year – named by the Roman Emperor, Augustus, to honor himself – evokes memories of very warm, very humid...more
Head-Scratchers- The Code is chock-full of provisions that will challenge the intellectual capacity, not to mention the patience, of most tax professionals. The complexity of these rules does not arise out of some sadistic...more
Extra, Extra!- Last Friday afternoon, as millions of unsuspecting Americans prepared for the long Memorial Day weekend – for many, perhaps, their first mask-less holiday celebration in almost 15 months – the Biden...more
This guidebook is designed to serve as an interactive reference for individuals in Washington state looking for information and resources available to help with the financial impacts of COVID-19. It is not legal advice and...more
“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...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
On November 18, the U.S. Treasury Department and Internal Revenue Service (IRS) released guidance clarifying the tax treatment of expenses where a Paycheck Protection Program (PPP) loan has not been forgiven by the end of the...more