The “Inflation Reduction Act of 2022” recently announced by Senators Manchin and Shumer to be added to the 2022 Budget Reconciliation bill proposes several significant changes to Section 1061 of the Internal Revenue Code of...more
On July 31, 2020, the Internal Revenue Service and the U.S. Treasury Department issued Proposed Treasury Regulations (the “Proposed Regs”) providing guidance under the “carried interest” rules of Section 1061 of the Internal...more
The discussion in this Quick Study Supplement outlines select federal income tax issues “C” corporation borrowers may face in debt restructurings. As noted in our debt restructuring overview Quick Study, a borrower generally...more
Distressed economic climates can produce unique circumstances for a lender. As a borrower defaults on payments or breaches financial covenants, a lender may reexamine its tax reporting around the borrower’s debt (e.g.,...more
The discussion in this Quick Study Supplement outlines select federal income tax issues partnership borrowers may face in debt restructurings. As noted in our debt restructuring overview Quick Study, a borrower generally...more
The discussion in this Quick Study Supplement outlines select federal income tax issues “S” corporation borrowers may face in debt restructurings.1 As noted in our debt restructuring overview Quick Study, a borrower generally...more
As the economic impact of COVID-19 continues to evolve, many businesses are looking to restructure their debt to help navigate through the crisis. In the past several weeks, lenders have been inundated with such requests,...more
On December 15, the House and Senate Conference Committee released the conference report on the Tax Cuts and Jobs Act (the “Conference Committee Report” or “Report”), containing the specific details on the tax plan they hope...more