News & Analysis as of

Debtor-Creditor Corporate Taxes

Foley & Lardner LLP

The Effect of Tax Reform on Financing Transactions: Thoroughly Review Your Company's Situation

Foley & Lardner LLP on

In general, the effects of the new tax law should be very favorable to most corporate borrowers. Nevertheless, there may be situations where a corporate borrower benefits economically from a lower tax rate and other favorable...more

Farrell Fritz, P.C.

Debt vs. Equity: Form & Substance Matter

Farrell Fritz, P.C. on

Some lessons need to be repeated until learned. It’s a basic rule of life. Don’t tug on Superman’s cape; don’t spit into the wind; don’t pull the mask off that old Lone Ranger; and if you are going to make a loan, give it the...more

Farrell Fritz, P.C.

Loans Between Related Entities

Farrell Fritz, P.C. on

What Was Intended? Over the last thirty years, I have reviewed the income tax returns of many closely held corporations and partnerships. Quite often, on Schedule L (the balance sheet), I will see an entry for “other...more

McDermott Will & Emery

SALT Implications of Proposed Section 385 Debt/Equity Regulations

McDermott Will & Emery on

Determining the difference between debt and equity is a problem that has bedeviled taxpayers and tax administrators for decades. Taxpayers, recognizing that there are tax advantages to financing a corporation with debt (e.g.,...more

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