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Corporate Taxes › Internal Revenue Service › Debt Securities

Kramer Levin Naftalis & Frankel LLP

New Section 162(m) Proposed Regulations

Kramer Levin Naftalis & Frankel LLP on

The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more

Locke Lord LLP

New Tax Rules May Cause Changes in High Yield Deals and Credit Facilities with Upstream Guarantees

Locke Lord LLP on

The details of new tax rules are described in this Locke Lord Quick Study from our tax and finance colleagues. From a capital markets perspective, the new tax rules open up interesting possibilities. For decades, companies...more

Fenwick & West LLP

Section 385 Proposed Regulations

Fenwick & West LLP on

On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code. Issued the same day as the anti-inversion temporary regulations, the proposed § 385 rules would go much farther than merely...more

Alston & Bird

A Reverse Morris Trust Ruling

Alston & Bird on

LTR 201542004 at first seems to involve a standard spinoff for the purpose of pursuing a reverse Morris Trust combination of Controlled with a Merger Partner, with the “significant issue” for ruling being a proposed swap of...more

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