News & Analysis as of

Tax Deductions Loans

Cadwalader, Wickersham & Taft LLP

Examining "Purpose"

The recent Upper Tribunal (“UT”) decision in JTI Acquisitions Company (2011) Ltd v HMRC [2023] UKUT 194 (TCC) has further illuminated the interpretation and application of the “unallowable purposes” rule in the UK’s loan...more

Rivkin Radler LLP

Generating Tax Losses as a Hobby

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Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more

Cadwalader, Wickersham & Taft LLP

HMRC v BlackRock Holdco 5 LLC Throws a Spotlight on UK Transfer Pricing and the ‘Unallowable Purposes’ Rule

A decision in late-July 2022 of the UK’s Upper-tier Tax tribunal (“UTT”) has held that interest recognized by a UK resident company on loan notes issued to its parent was non-deductible under the UK transfer pricing rules, as...more

Proskauer - Tax Talks

Summary of the Biden Administration’s Fiscal Year 2023 Green Book Tax Proposals

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On March 28, 2022, the Biden Administration released the Fiscal Year 2023 Budget, and the “General Explanations of the Administration’s Fiscal Year 2023 Revenue Proposals,” which is commonly referred to as the “Green Book.” ...more

Rivkin Radler LLP

Biden’s Proposed Income Tax Increases And The Sale Of The Baby Boomer Business

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“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more

Dickinson Wright

Deductions Available for Certain Expenses Paid with PPP Loan Proceeds

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In March, 2020, the CARES Act established the Paycheck Protection Program which provided loans (“PPP loans”) to businesses meeting certain requirements. Subject to certain limitations, PPP loan recipients are entitled to have...more

Bowditch & Dewey

2020 End of Year Tax Planning for Individuals

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As the 2020 year draws to a close, families should review with their tax advisers the CARES Act tax-related provisions in their tax and financial planning. Tax provisions that apply to individuals include the following: ...more

Farrell Fritz, P.C.

Transfer Of Funds between Related Entities – Indebtedness Or Something Else?

Farrell Fritz, P.C. on

A closely held business may come to our firm for any number of reasons. The owners may be selling the business, for example, or they may be thinking about spinning off a division. In some cases, the owners are considering the...more

Troutman Pepper

When Does a Loan Guarantee Provide Amounts at Risk - Tax Update, Volume 2020, Issue 3

Troutman Pepper on

In Bordelon v. Commissioner, the Tax Court addressed the circumstances under which an individual’s personal guarantee of a loan to his single-member LLC established sufficient amounts at risk to enable him to claim more than...more

BakerHostetler

No Deduction Allowed for Expenses Resulting in PPP Forgiveness

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Ending weeks of speculation and debate, the IRS has issued guidance confirming that no deduction is allowed for an otherwise deductible expense if the payment of the expense results in forgiveness of a Paycheck Protection...more

White & Case LLP

Interest related to leveraged capital reduction or dividend distribution not always tax deductible, according to the Supreme Court

White & Case LLP on

The Supreme Court has ruled that interest on a loan contracted in order to carry out a capital reduction or a dividend distribution when the company lacks the liquidity to do so is not always deductible. It is crucial that...more

White & Case LLP

European Real Estate Finance: Recent developments – June 2019

White & Case LLP on

As part of our periodic updates, here is an overview of recent developments of relevance to participants in the real estate finance market across certain key jurisdictions in Europe....more

McDermott Will & Emery

Changes in Executive Compensation

In a presentation at McDermott’s Employment and Employee Benefits Forum, Andrew Liazos discussed areas of focus for Section 162(m) and third-party loan funding for employee stock purchase plans (ESPPs). He also provided...more

Maynard Nexsen

Employee Benefits and the Tax Cuts and Jobs Act

Maynard Nexsen on

As we move into the second quarter of 2018, now is a good time to remind employers about the significant impact of the Tax Cuts and Jobs Act (TCJA) on employee benefits. While some of these issues may not affect the taxation...more

Morrison & Foerster LLP

Indiana Tax Court Allows Deductions for Interest Paid on Intercompany Loans and Holds That Gain from Sale of Partnership Was...

On July 11, 2017, the Indiana Tax Court released a decision in E.I. DuPont de Nemours and Company v. Indiana Department of State Revenue. The Tax Court held that the Indiana Department of Revenue had improperly reclassified...more

Seyfarth Shaw LLP

Presidential Pulse: 10 Key Ways the Trump Administration May Impact The Way You Do Business in 2017

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Today marks just over a month since Donald Trump was elected as the next President of the United States. As each cabinet appointment is announced, we get more clues to help us predict which direction the Trump...more

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