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Beware of Debtor Tax Traps in Restructuring and Bankruptcy

The economic outcome from the coronavirus (COVID-19) pandemic is still uncertain but is likely to remain catastrophic in many respects. Of late popular name brands and companies have filed for bankruptcy as stay-at-home...more

Proposed Regulations Would Modify the Application of Section 956 to Many Financing Transactions

The proposed modifications would create opportunities for enhanced CFC credit support. On October 31, 2018, the US Treasury Department and the Internal Revenue Service (IRS) released proposed Treasury Regulations (the...more

M&A and Tax Reform—New Tax Considerations with Wide-Ranging Implications

New tax provisions have significant impact on structuring mergers and acquisitions. In light of the recent passage of HR 1 (the Act) and ensuing sweeping changes to tax law in the United States, certain tax-related aspects...more

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