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Podcast: Questions & Concerns About Documentation: A Conversation with Colin Adams, M-III Partners
This column describes new proposed Code Sec. 163(n) and the proposed general removal of expense allocation to GILTI in the Build Back Better Act (the “BBBA”). This column focuses on the version of the BBBA proposed on...more
The window for the Main Street Loan Program (“Main Street Program”), designed to provide loans with favorable terms to midsize companies to help address the economic fallout caused by the pandemic, is closing on December 31,...more
Effective July 6, 2020, the Federal Reserve Bank of Boston announced that the “Main Street Lending Program” is now fully operational and ready to begin purchasing commitments from eligible lenders. After months of periodic...more
On June 15, 2020, the Federal Reserve announced the launch of its Main Street Lending Program (“Main Street Program” or “Program”) under the CARES Act. This Program was created to provide up to $600 billion in liquidity to...more
Congress recently passed the economic stimulus package referred to as the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act1”), the Paycheck Protection Program and Health Care Enhancement Act (“PPPHCE Act”),...more
The Main Street Lending Program, authorized under the CARES Act and Section 13(3) of the Federal Reserve Act, is designed to provide financial assistance to small and medium sized businesses. There will be three Main Street...more
Federal Reserve Chairman Jerome Powell announced on May 19, 2020, before a Senate Committee that the Main Street Lending Program (Program) is anticipated to be launched around the end of May. Prospective borrowers should be...more
The Federal Reserve Bank (the “Fed”) and the U.S. Department of the Treasury (the “Treasury”) announced preliminary details for the Main Street Lending Program (the “MSLP”) on April 9, 2020. Additional details and guidance as...more
On April 30, 2020, the Department of the Treasury and the Federal Reserve Board released a set of “Frequently Asked Questions” (FAQs) relating to the Main Street Business Lending Program (Main Street Program), which was...more
When the Federal Reserve Board announced its Main Street Lending Program, it was unclear whether nonprofits would be eligible. On April 30, 2020, the Feds clarified that nonprofits are not eligible for the Program and noted...more
In a recent alert, we reviewed a series of developments regarding implementation of the $2.2 trillion federal CARES Act, including news that the Federal Reserve had released details on two new loan facilities. This alert...more
U.S. Treasury Secretary Steven T. Mnuchin approved the establishment of a Main Street Business Lending Program to support the flow of credit to American workers, businesses, states, counties and cities impacted by the...more
Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that...more
In long-awaited guidance on Section 163(j) post-tax reform, the Treasury and IRS present taxpayers with an expansive definition of “interest,” subjective anti-abuse rules, complex computational instructions, and several...more
On November 26, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated regulations regarding the new section 163(j) limitation on business interest deductions. Section 163(j) was modified as...more
On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory...more