Law Firm ILN-telligence Podcast | Episode 80: Peter Fousert, PlasBossinade | The Netherlands
What to Do if Your Suppliers Are in Distress - Options Beyond Contract Termination or Default
Commercial Recovery
Cannabis and Bankruptcy Laws
Part 2: Additional Implications for Cryptocurrency Companies in Bankruptcy
Kasey Ingram and Rocco Debitetto on Bankruptcy and Compliance
Ingram and Debitetto on Bankruptcy and Compliance Programs
M&A Strategies for the Acquisition of Insolvent/Financially Distressed Targets
Blakes Continuity Podcast: What to Expect When Insolvency Crosses the Border
THE ACCIDENTAL ENTREPRENEUR PART III
Using Prepackaged Plans to Speed Through Bankruptcy Courts by Veronica Polnick
Restructuring in the Time of COVID-19
Bankruptcy Basics and Recent Developments
Investment Management Update – Exit Strategies
Bill on Bankruptcy: Kodak Plan Bumps the Debt, Craters Stock
On July 17, the U.S. Treasury and IRS released final regulations targeting various inbound cross-border transactions broadly referred to as “Killer B” transactions, marking the end (for now) of a long-running regulatory fight...more
Disagreements happen. In the corporate context, one or more shareholders may share a different vision for the company than the other shareholders. Or, there may be acrimony amongst the shareholders for other reasons, as can...more
In Leto v. United States, the taxpayer reincorporated an S corporation business into a C corporation, then the taxpayer later sold the shares in the C corporation and tried to exclude the gain from such sale under section...more
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more
W 2022 r. na stronie Rządowego Centrum Legislacji opublikowano projekt Ustawy o zmianie ustawy — Kodeks spółek handlowych oraz niektórych innych ustaw (dalej: „Projekt”). Zakłada on dodanie do Kodeksu Spółek Handlowych...more
In 2022, a bill aimed at amending the Polish Commercial Companies Code and certain other Acts was published on the website of the Government Legislation Centre (hereinafter: the “Project”). The Project adds provisions to the...more
I. Introduction F reorganizations, much like the game of Othello, can take a minute to learn but a lifetime to master. They are often a critical part of structuring the purchase and sale of S corporations. As part of an F...more
The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more
The Upper tax tribunal (“Upper Tribunal”) has confirmed the decision of the First-tier tax tribunal (“FTT”), delivered in 2021, in the case of Kwik-Fit Group Limited and others v HMRC. This decision of the Upper Tribunal...more
Headlines - - Tax Issues for F Reorganizations in M&A Transactions - Presidential Executive Order Places Heightened Importance on National Security Risks and Committee on Foreign Investments in the United States...more
This webinar will go into detail about the advantages and disadvantages of using an F-reorganization as a tax strategy when selling your S-Corporation and will discuss the following topics: - What is an F-reorg for...more
Partnerships are ineligible S corporation shareholders. So, a partnership cannot acquire shares in an S corporation without terminating that corporation’s S election. However, a partnership can still invest in an S...more
Brief commentary on the recent developments, cases, rulings, notices, and related federal tax guidance. Biden Administration Budget Proposal May Limit Tax-Free Reorganizations for Corporations with Preferred Stock...more
Corporate reorganizations and spin-off transactions are transactions where there is often a great deal of incentive to qualify for tax-free treatment. In many cases, the amount of tax at issue justifies obtaining a private...more
Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Corporations Permitted to Rely on Public Shareholder Data to Confirm Qualification for Tax-Free Spin-off and Subsequent Merger...more
Former British Prime Minister Winston Churchill once said, “Plans are of little importance, but planning is essential.” Perhaps that quote is a tad strong to apply generally to corporate reorganizations under Section 368 of...more
Funding expensive obligations for retiree health benefits, often an impediment to running a financially stable business or even successfully navigating a Chapter 11 bankruptcy process, may no longer present such a problem—at...more
On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more
Even with the bill still in Conference, here are some things businesses should follow closely. Both House and Senate Bills call for deemed repatriation of accumulated foreign profits at reduced tax rates. ...more
In June 2005, the Internal Revenue Service (IRS) issued a package of proposed regulations providing that certain corporate liquidations, formations and reorganizations would not qualify for nonrecognition treatment if the...more
Proposed regulations issued on July 14, 2016 generally would prevent tax-free spinoffs involving companies with less than 5% active business assets and spinoffs where one company holds a substantial amount of nonbusiness...more
LTR 201542004 at first seems to involve a standard spinoff for the purpose of pursuing a reverse Morris Trust combination of Controlled with a Merger Partner, with the “significant issue” for ruling being a proposed swap of...more
In late September, the IRS issued final regulations describing six requirements for a transaction or series of transactions to qualify as a reorganization under Section 368(a)(1)(F) (an “F reorganization”). The IRS...more
One of the great features of corporations is that liability in the corporation generally does not extend to its shareholders, including tax liability. Like any rule, though, there is almost always an exception. In this...more