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Income Taxes › Debt

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Cadwalader, Wickersham & Taft LLP

Burlington: Good News for the Secondary Debt Market

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In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more

Jones Day

Internal Revenue Service Alters Its View on Section 355 Spin-Offs

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The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more

Rivkin Radler LLP

This Thanksgiving, Give Thanks for Taxes . . . or Not

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Thanksgiving has been a national holiday in the U.S. since 1870. During most of that period, at least until recently, it has also been a unifying force as immigrants to this country, eager to be assimilated to American...more

Rivkin Radler LLP

Sale of Mortgaged Property – Amount Realized or COD Income

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Do you feel as challenged as I do when someone asks you to explain the term “Bidenomics”? I know that it is predicated upon the imposition of higher taxes on businesses and their owners, which have not yet materialized....more

Winstead PC

[Virtual Half-Day Seminar] Real Estate Startup - April 18th, 9:00 am - 12:15 pm CST

Winstead PC on

On April 18, join Winstead attorneys Trip Dyer, Ben Gehlbach, Daniel Bell-Garcia, Jacob Loehr, Matt Dzura, and Cole Gearhart, along with Whitley Penn Partner Shea Krachek, for our Real Estate Startup half-day virtual seminar....more

Rivkin Radler LLP

Selling Your Business? Take the Money But Defer the Tax?

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Sale of the Business- Imagine Client has just received an attractive, all cash offer for the sale of their business; there is no financing contingency. The buyer has proposed a cash-free and debt-free deal....more

Goodwin

Luxembourg Tax Authorities Issue Administrative Guidance On Application Of Interest Limitation Rules

Goodwin on

On 8 January 2021, the Luxembourg Tax Authorities published a Circular clarifying the interest limitation rules introduced in Luxembourg legislation in 2018, which implemented the European Union Anti-Tax Avoidance Directive...more

Foster Garvey PC

There Is a Santa Claus After All – Lawmakers Deliver a Wonderful Holiday Gift to Businesses and Their Owners in a Time of Need

Foster Garvey PC on

The Consolidated Appropriations Act, 2021 - In a bipartisan effort, H.R. 133-116th Congress: Consolidated Appropriations Act, 2021 (the "Consolidated Appropriations Act, 2021") overwhelmingly passed both the House and the...more

McNees Wallace & Nurick LLC

McNees Insights – Estate Planning: March 2019

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Estate Planning for Real Estate Owners - Estate planning for valuable, illiquid assets presents a variety of challenges. With respect to real estate, planning challenges can be compounded due to fractional ownership, outside...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

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“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

Hogan Lovells

Waiver of contractual right

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In a binding private ruling published on 2 May 2017, SARS was requested to confirm the income tax, donations tax, capital gains tax and value-added tax consequences of the proposed waiver of a right to receive an annual...more

Hogan Lovells

Budget 2017

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The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more

Troutman Pepper

Tax Developments in 2016: Federal Tax (Part I) - Sections 355, 382, and 385; and new rules on partnership audits dominate...

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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

McDermott Will & Emery

SALT Implications of Final Section 385 Debt-Equity Regulations

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The recently released final regulations under Internal Revenue Code Section 385, addressing the circumstances under which related company debt will be classified as equity for federal income tax purposes, will have a...more

Dechert LLP

New Proposed Regulations Increase Scrutiny on Related-Party Debt

Dechert LLP on

The U.S. Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently issued proposed regulations (the “New Proposed Regulations”) governing the federal income tax treatment of debt between certain related...more

Eversheds Sutherland (US) LLP

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Eversheds Sutherland (US) LLP on

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

Latham & Watkins LLP

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

Eversheds Sutherland (US) LLP

Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes

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On April 4, the Treasury and the Internal Revenue Service (IRS) released proposed regulations under IRC § 385 (the Proposed Regulations) that are intended to combat perceived concerns associated with indebtedness between...more

Ballard Spahr LLP

IRS Proposes To Eliminate ‘Confusing’ 36-Month Non-Payment Testing Period for Cancellation of Debt

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The Internal Revenue Service recently proposed very well-received regulations under Section 6050P of the Internal Revenue Code (the Code) that would eliminate the requirement for financial entities to treat debt as canceled...more

Miller & Martin PLLC

IRS Creates New Disregarded Entity Exclusion from Debt Cancellation Income

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The IRS has announced a new safe harbor from the discharge of debt income rules. Debt that is cancelled, discharged or forgiven is generally taxable as income, but there are exceptions. Under one exception, certain...more

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