At the onset of its second term, the Trump Administration made clear that the United States opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules, (“GloBE” or “Pillar 2”)....more
On January 14, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations (the “Final Regulations”) addressing reporting obligations with respect to certain...more
As a number of debt instruments issued several years ago in a relatively low interest rate environment now have their maturity date approaching in a much higher interest rate environment, borrowers are increasingly seeking to...more
The global COVID-19 pandemic has placed an unprecedented stress on the ability of businesses to service their debt. Certain businesses—such as oil and gas, airlines, cruise lines, hospitality, brick-and-mortar retailers, and...more