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Lenders › Controlled Foreign Corporations

Kramer Levin Naftalis & Frankel LLP

IRS Paves the Way for Lenders to Obtain Guarantees and Collateral From (and 100% Stock Pledges of) Foreign Subsidiaries

Kramer Levin Naftalis & Frankel LLP on

Background On Oct. 31, 2018, the Internal Revenue Service issued proposed regulations under Section 956 of the Internal Revenue Code that will eliminate the adverse tax consequences when a U.S. parent corporation (i)...more

Jones Day

Proposed Treasury Regulations Permit Foreign Subsidiary Credit Support for U.S. Multinational Financings

Jones Day on

The proposed regulations, released October 31, 2018, generally provide tax-free treatment to a U.S. corporate parent of a controlled foreign corporate subsidiary ("CFC") for deemed dividends triggered when the CFC provides...more

Bracewell LLP

Focus on Finance: Tax Reform and the Banking Industry Revisited

Bracewell LLP on

The Tax Cuts and Jobs Act (TCJA) has far-reaching implications for the banking and finance industry. In our very first Bracewell Tax Report, we noted certain issues that companies might consider when evaluating their...more

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