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Corporate Taxes › Tax Cuts and Jobs Act › Loans

Rivkin Radler LLP

The Biden Administration’s Revenue Proposals For Fiscal Year 2022: Tax Increases And Forced Recognition Of Capital Gains

Rivkin Radler LLP on

Extra, Extra!- Last Friday afternoon, as millions of unsuspecting Americans prepared for the long Memorial Day weekend – for many, perhaps, their first mask-less holiday celebration in almost 15 months – the Biden...more

BakerHostetler

IRS Issues Regulations That May Affect Borrowing Costs and Financing Terms of US Multinationals

BakerHostetler on

Recently proposed IRS regulations materially change the way stock and assets of foreign corporations that are “controlled foreign corporations” (CFCs) can be used to support debt of U.S. affiliates. ...more

Latham & Watkins LLP

Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction

Latham & Watkins LLP on

Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct. On August 6, 2018, the US Tax Court decided...more

Orrick, Herrington & Sutcliffe LLP

Tax Issues When Fixing Rate and Fee Adjusters in Tax-Exempt Loans

Orrick, Herrington & Sutcliffe LLP on

The recently enacted reduction of the maximum federal corporate tax rate may trigger contractual provisions that provide for a significant increase in the interest rate on tax-exempt debt privately placed with a bank lender...more

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