Convertible debt is exceptionally attractive to investors in volatile markets because it offers the security of a bond with the upside of equity. That is why convertible debt was one of the strongest asset classes during the...more
1/4/2022
/ Convertible Bonds ,
Convertible Debt ,
Corporate Financing ,
Corporate Issuers ,
Corporate Taxes ,
Dilution ,
Equity Financing ,
Equity Markets ,
Equity Securities ,
FIRPTA ,
Hedging ,
Investors ,
PFIC ,
Tax Deductions ,
Tax Planning
Volatile trading markets and economic instability may prompt taxpayers to modify, purchase, or repurchase debt; participants should consider the tax consequences.
Key Points:
..Issuers may incur immediate income in the...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects.
On November 26, 2018, the Treasury and...more
12/20/2018
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
GILTI tax ,
Interest Payments ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
The IRS announces certain key aspects of the interest deduction limitation that will be addressed in upcoming Treasury regulations.
Key Points:
..The 30% Cap (as defined below) will apply at the consolidated group...more
The new tax rules are expected to have an immediate impact on leveraged companies and leveraged finance transactions.
On December 22, 2017, President Trump signed into law the “Tax Cuts and Jobs Act” (the Act).1 This...more