Corporate Taxes, Debt-Equity

Understanding Tax: Opportunities arising from the new UK Hybrid Capital Instruments Regime

White & Case LLP on 3/30/2020

This article is produced by our London Tax team, which is part of our global Tax practice. Our series, "Understanding Tax", explores commercially relevant and recent changes to the UK's tax code. Opportunities arising from...more

Coronavirus/COVID-19 Update #2

Skadden, Arps, Slate, Meagher & Flom LLP on 3/21/2020

The question is no longer whether the volatility created by the COVID-19 pandemic will deepen the difficulties businesses and other institutions face in the coming months, but by how much and in what ways. In the past few...more

Loans to U.S. Subsidiaries Should Be Carefully Structured and Documented to Obtain U.S. Tax Benefits

Dorsey & Whitney LLP on 8/18/2017

Canadian companies should carefully structure and document loans and advances to their U.S. subsidiaries. If loans to U.S. subsidiaries are not properly structured and documented, such loans may be recharacterized as equity...more

Focus on Tax Strategies & Developments - December 2016

McDermott Will & Emery on 12/13/2016

Significant Changes in US Tax System Likely - In the short time since the surprising election of Donald J. Trump as the 45th president of the United States, much already has been written about the likelihood and likely...more

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

Proskauer - Tax Talks on 11/2/2016

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

"IRS and Treasury Issue Final Debt/Equity Regulations"

Skadden, Arps, Slate, Meagher & Flom LLP on 10/26/2016

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

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

Skadden, Arps, Slate, Meagher & Flom LLP on 7/6/2016

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

Corporate Taxes › Debt-Equity