Closed-end investment companies registered under the Investment Company Act of 1940, as amended (the "1940 Act"), have proven to be a product sought by many investors, especially individuals. Despite their appeal to long-term...more
Over the past year and half, interest rates have increased significantly. For most investors, the increase in interest rates is welcome. But for issuers of tax-exempt bonds, or cities, states and other qualifying governmental...more
Sometimes the first step to solving (or mitigating or avoiding) problems is to identify what the problem may be to, among other things, put time on one’s side. For issuers of tax-exempt municipal bonds, there tend to be...more
As of this date, the Federal Open Market Committee (FOMC) has increased short-term interest rates eleven times in the last sixteen months to combat inflation. As a result, interest rates on short-term investments have...more
A number of our clients have recently inquired as to their responsibilities with respect to arbitrage rebate for their tax-exempt borrowings. The dramatic increase in the return on short-term investments is raising the...more
What is arbitrage? Generally, arbitrage is the simultaneous buying and selling of securities in different markets to exploit the difference in pricing. Specific to the tax-exempt bond market, arbitrage arises when a...more
This bulletin discusses pending actions of the (a) National Association of Insurance Commissioners (NAIC) Valuation of Securities (E) Task Force (VOS Task Force) to address certain issues associated with insurer investments...more
At its July Open Commission meeting, the Federal Communications Commission’s (FCC or Commission) voted to approve a Notice of Apparent Liability for Forfeiture (NAL) against Thomas Dorsher, ChariTel Inc, OnTel Inc, and...more
This article focuses on the use of Split Dollar life insurance and the use of the Leveraged Split Dollar RolloutTM technique combining the tax arbitrage of life insurance with the financial arbitrage of Split Dollar life...more
Returns from Asia-Pacific merger arbitrage positions have proved consistently attractive over time, offering the additional benefit of portfolio diversification when compared to other equity strategies where returns are more...more
A mounting death toll (over 106 and counting) and fears of a coronavirus pandemic sent markets tumbling early on Monday and kicked off a selloff that continued all day....more
The shock waves from the German authorities’ tax evasion investigation into cum-ex transactions, a complex form of dividend arbitrage, continue to be felt throughout Europe. A large number of UK and European financial...more
On September 19, the Securities and Exchange Commission’s Investor Advisory Committee held a hearing to discuss the risks of increased leverage in the loan market and the potential impact leveraged loans and collateralized...more
On March 30, 2018, the U.S. District Court for the Southern District of Ohio issued an order substantially denying defendants’ Motion to Dismiss the Federal Energy Regulatory Commission’s (FERC or the “Commission”) Complaint...more
New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Cryptocurrency-related Holdings - On January 18, 2018, the staff of the SEC’s Division of Investment...more
The Director of the U.S. Securities and Exchange Commission (SEC) Division of Investment Management has outlined concerns of the SEC Staff (Staff) with respect to the registration of funds that hold cryptocurrencies and...more
On January 18, 2018, the Securities and Exchange Commission’s (SEC) Division of Investment Management broke its relative silence regarding the recent growth of cryptocurrencies and cryptocurrency-related products. While...more
CSSF Statement Confirming Support of ESMA's Position on Supervisory Convergence/Regulatory Arbitrage - The CSSF published a statement confirming its support of ESMA’s position on the matter of supervisory convergence /...more
SEC/CORPORATE - Delaware Chancery Court Decision Demonstrates Continuing Risk to “Appraisal Arbitrage” In a stark application of the adage that one should be careful what one wishes for—because one may get it—on May 30,...more
The FCA has outlined the current trends, risks and its overall assessment of the General Insurance sector in its 2017 Sector Views, published last week. ...more
On December 9, 2016, the Department of the Treasury and Internal Revenue Service (IRS) published final regulations on the definition of “issue price,” for purposes of the arbitrage rules that apply to tax-exempt bonds....more
Introduction to Tax for Public Finance - • What is the tax-exemption for state and local bonds? • Types of tax-exempt bonds • Overview of federal income tax requirements... ...more
After two sets of proposed regulations, Treasury and IRS have now released final regulations on the definition of “issue price” for purposes of arbitrage investment restrictions that apply to tax-advantaged bonds (the “Final...more
For a variety of reasons related to arbitrage, it often is important to identify the "issue price" of tax-exempt bonds with precision and certainty. Existing Treasury Regulations generally allow the "issue price" of publicly...more
This update provides a summary of recent Delaware caselaw and statutory developments concerning mergers and acquisitions, including new cases regarding appraisal rights, fraud claims and fiduciary duty and deal process...more