Podcast: Credit Funds: Credit Default Swaps in the Distressed Limelight
Podcast: Credit Funds: What Managers Need to Know and Practical Tips to Avoid Insider Trading Risks
As the end of 2024 draws to a close, Luxembourg aims to introduce an interesting technical update that may globally be of interest for our clients with structures in Luxembourg. On 11 December 2024, the Luxembourg...more
In Short: The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more
On December 30, 2021, the Treasury Department and IRS issued final regulations to address the taxability of modifications that replace LIBOR or another interbank offered rate (an IBOR) with a qualified rate like SOFR....more
FASB has issued a proposed Accounting Standards Update, or ASU, intended to improve guidance used to determine whether debt should be classified as a current or noncurrent liability in a classified balance sheet....more
Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more
On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the “Final” or “Temporary” Regulations) under Internal Revenue Code section 385. These regulations, which consist of both temporary...more
On October 22, 2016, the Treasury finalized the debt/equity regulations under Section 385 it had proposed in April. The 517-page package can daunt even the most motivated readers. “Expanded groups” (EG) that know they will be...more
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385. The final and temporary regulations recharacterize certain debt instruments as equity for...more