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Interest Payments Lenders

Bilzin Sumberg

Tax Considerations for Contingent Interest and Convertible Debt in Cross-Border Lending Transactions

Bilzin Sumberg on

The treatment of contingent interest and convertible debt in cross-border payment transactions is subject to several provisions of the Internal Revenue Code. To add confusion to the already complicated subject, the...more

Cadwalader, Wickersham & Taft LLP

Second Circuit Rules in Favor of Citibank in Accidental $500m Transfer in Revlon Loan Transaction

In a decision rendered September 8, 2022, a three-judge panel for the United States Court of Appeals for the Second Circuit (the “Court”) vacated a February, 2021 decision by the United States District Court for the Southern...more

Paul Hastings LLP

Thin Capitalization Tax Rules Finally Applied in Court —Tokyo District/High Courts Deny Tax Deductibility of Interest Paid to a...

Paul Hastings LLP on

The thin capitalization tax rules (the “Thin Capital Rules” or the “Rules”) were incorporated into our tax statute in 1992. Then no cases appeared in courts for almost three decades. Recently, however, a new case appeared in...more

Manatt, Phelps & Phillips, LLP

Important Banking Development From California Courts

Courts in California delivered some important banking developments in two recent decisions, with a federal court finding a charge for failing to replenish an overdrawn account constituted interest while the state's highest...more

Kramer Levin Naftalis & Frankel LLP

Is Bank Debt a Security?: Dangerous Implications of the General Motors Litigation

GM’s term lenders had received $28 million in cash interest during the 90 days prior to GM’s filing, and $1.5 billion in full payment during the bankruptcy, subject to disgorgement if the term lenders proved to be...more

BCLP

Corporate Trustees and Cash Managers: can historic miscalculations and underpayments be an Event of Default? The English High...

BCLP on

We now have the English High Court’s first judgment concerning the position of Class X Notes in a CMBS structure. The rights of the Class X Notes in the Windermere VII CMBS were considered by the Court in Hayfin Opal Luxco 3...more

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