News & Analysis as of

U.S. Treasury › Corporate Financing

Holland & Knight LLP

Breaking the "Equity Wall": Proposed Regulations Limit Chances to Minimize U.S. Withholding Tax

Holland & Knight LLP on

The U.S. Department of the Treasury (Treasury) issued proposed regulations (the Proposed Regulations) on April 8, 2020, that would restrict foreign persons' ability to minimize U.S. tax through "conduit" financing...more

Allen Matkins

Favorable Guidance Issued on Opportunity Zones

Allen Matkins on

On April 17, 2019, the Treasury Department released a second set of proposed regulations on opportunity zones. These newly proposed regulations address many key issues in a manner that is generally favorable for taxpayers,...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

Latham & Watkins LLP

New Proposed Treasury Regulations May Eliminate Adverse Tax Consequences on Use of Foreign Credit Support for US Corporate...

Latham & Watkins LLP on

But Holding Period and Other Requirements Add Complexity - On October 31, 2018, the US Treasury and Internal Revenue Service issued proposed regulations (the Proposed Regulations) that would eliminate, in most...more

Katten Muchin Rosenman LLP

New Proposed Rules Limit the Negative Tax Consequences of Section 956 "Deemed Dividends" - Certain Foreign Guarantees and Stock...

Katten Muchin Rosenman LLP on

On October 31, the Internal Revenue Service (IRS) released proposed regulations (the "Proposed Regulations") under Section 956 that could substantially increase the collateral packages made available by US corporate borrowers...more

A&O Shearman

Brexit and Other Key Issues for CFOs and Corporate Treasurers

A&O Shearman on

On June 23, 2016, the UK electorate voted to leave the European Union in an advisory Referendum. We expect the UK Government to commence negotiations to withdraw and to establish a framework for the UK’s new relationship with...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Proposed Treasury Regulations Revolutionize Tax Rules Governing Intercompany Financing Transactions"

Skadden, Arps, Slate, Meagher & Flom LLP on

Recently proposed Treasury regulations, which will likely be finalized this year, promise to alter the tax treatment of a wide range of intercompany financing transactions dramatically, upending nearly a century of law...more

Dechert LLP

Recent Developments in Acquisition Finance

Dechert LLP on

Recent legal and regulatory developments have raised issues for those considering a loan-to-own acquisition strategy, and have continued to impact both the structure of highly leveraged financings and the makeup of those...more

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