Tax Reform, Borrowers

New York Lawmakers Re-introduce Legislation to Impose Recording Tax on Mezzanine Loans and Preferred Equity Investments

White and Williams LLP on 2/2/2023

New York State lawmakers have reintroduced proposals to impose a tax on the creation of mezzanine debt and preferred equity. Both the New York Senate and Assembly have put forward similar bills that would require both...more

The Taxpayer First Act and the Impact on Secondary Market Participants

Mayer Brown on 2/12/2020

The Taxpayer First Act (the “Act” or “TFA”) imposes new limits on the disclosure of US taxpayer tax information obtained on or after December 28, 2019. The Act is designed, among other things, to overhaul and modernize...more

Upstream guarantees and security by foreign subsidiaries of a U.S. corporate borrower may now be available without adverse U.S....

Hogan Lovells on 6/12/2019

Tax structuring under the previous regime - Prior to the issuance of the final regulations described below, under Section 956 of the Internal Revenue Code of 1986 and its related Treasury Regulations, for U.S. tax...more

Tax Reform › Borrowers

New York Lawmakers Re-introduce Legislation to Impose Recording Tax on Mezzanine Loans and Preferred Equity Investments

The Taxpayer First Act and the Impact on Secondary Market Participants

Upstream guarantees and security by foreign subsidiaries of a U.S. corporate borrower may now be available without adverse U.S....

Newly Proposed US Tax Regulations Open Possibility of Full Credit Support from Foreign Subsidiaries

Proposed Treasury Regulations Impact “Deemed Dividend” Tax Rules in Financing Transactions

The Corporate Tax Rate Reduction and Reissuance Concerns

Proskauer’s Second Annual Survey on Trends in Private Credit Markets

Tax Reform’s Impact on Financing Strategies

Review and Analysis of Tax-Exempt Loan Documents Following Tax Cuts and Jobs Act

Tax Reform › Borrowers

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