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Tax Exemptions Borrowers

McGuireWoods LLP

Senior Living Alert: Federal Tax Code’s Arbitrage Rules May Impact the Return on Certain Investments

McGuireWoods LLP on

Borrowing money to finance capital projects is always more challenging in a rising interest-rate environment. However, one silver lining is the ability to earn more on the investment of borrowed money during the construction...more

Tonkon Torp LLP

PPP Round 2: Nonprofit Eligibility, Application Deadline, And Tax Impacts

Tonkon Torp LLP on

Shortly before the end of the bizarre and painful 2020 calendar year, the Consolidated Appropriations Act for 2021 (the Act) was signed into law, providing an additional $284 billion appropriation for the Paycheck Protection...more

Proskauer Rose LLP

Newly Proposed US Tax Regulations Open Possibility of Full Credit Support from Foreign Subsidiaries

Proskauer Rose LLP on

On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code (the "Proposed Regulations") that are likely to enhance the availability of...more

Moore & Van Allen PLLC

Proposed Treasury Regulations Impact “Deemed Dividend” Tax Rules in Financing Transactions

Moore & Van Allen PLLC on

Following tax reform at the end of 2017, cash dividends from a foreign corporate subsidiary to a domestic corporate 10 percent shareholder are exempt from U.S. income tax because the shareholder is permitted a...more

McNees Wallace & Nurick LLC

Review and Analysis of Tax-Exempt Loan Documents Following Tax Cuts and Jobs Act

On December 20, 2017 Congress passed the Tax Cuts and Jobs Act (TCJA). The legislation was signed by President Trump on December 22, 2017 and many key provisions of the law became effective on December 31, 2017....more

Morrison & Foerster LLP

The Private Placements Withholding Tax Exemption

Morrison & Foerster LLP on

The Finance Act 2015 introduced an exemption from a borrower’s obligation to withhold tax from interest payments arising on qualifying private placements. It was introduced to stimulate and grow the private placements market...more

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