On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more
11/9/2017
/ Collateralized Loan Obligations ,
Corporate Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
Legislative Agendas ,
Legitimate Business Interest ,
Pass-Through Entities ,
Securitization Vehicles ,
Tax Code ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
UBTI
On October 13, 2016, Treasury and the IRS issued new final and temporary “anti-inversion” regulations under section 385 of the Internal Revenue Code that could treat certain purchasers of notes issued by securitizations as...more
10/25/2016
/ Anti-Inversion Regulations ,
Asset-Backed Securities ,
Capital Markets ,
Collateralized Loan Obligations ,
Disregarded Entities ,
Grantor Trusts ,
IRS ,
Partnerships ,
Securitization ,
Stocks ,
Student Loans ,
Tax Rates ,
Transfer Restrictions ,
U.S. Treasury ,
Withholding Tax
On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more
10/25/2016
/ Asset Stripping ,
CDIs ,
Collateralized Loan Obligations ,
Convertible Debt ,
Debt Instruments ,
Debt-Equity ,
Exemptions ,
Expanded Group Instruments (EGIs) ,
Foreign Issuers ,
Interest Payments ,
Internal Revenue Code (IRC) ,
Inversion ,
IRS ,
Multinationals ,
Required Documentation ,
Stocks ,
Tax Rates ,
Transfer Restrictions ,
U.S. Treasury
Background -
Article 405 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU)...more