News & Analysis as of

Tax Deductions Lenders

Paul Hastings LLP

Thin Capitalization Tax Rules Finally Applied in Court —Tokyo District/High Courts Deny Tax Deductibility of Interest Paid to a...

Paul Hastings LLP on

The thin capitalization tax rules (the “Thin Capital Rules” or the “Rules”) were incorporated into our tax statute in 1992. Then no cases appeared in courts for almost three decades. Recently, however, a new case appeared in...more

Hahn Loeser & Parks LLP

IRS Disallows Deductions Funded With PPP Loans That Are Expected To Be Forgiven

Hahn Loeser & Parks LLP on

The Internal Revenue Service (“IRS”) ruled on November 18 that taxpayers that received Paycheck Protection Program (“PPP”) loans and used the proceeds to pay otherwise-deductible expenses may not deduct the payments if the...more

Kramer Levin Naftalis & Frankel LLP

IRS Paves the Way for Lenders to Obtain Guarantees and Collateral From (and 100% Stock Pledges of) Foreign Subsidiaries

Background On Oct. 31, 2018, the Internal Revenue Service issued proposed regulations under Section 956 of the Internal Revenue Code that will eliminate the adverse tax consequences when a U.S. parent corporation (i)...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

Foster Garvey PC on

“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

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