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Debt Multinationals

Jones Day

Business Restructuring Review Vol. 24, No. 4 | July–August 2025

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The Ad Hoc Group of Senior Secured Noteholders and DIP Lenders (the “Ad Hoc Group”) obtained a unanimous judgment in their favor in an appeal following Sanchez Energy Company’s long-running, hard-fought bankruptcy case. Once...more

A&O Shearman

Tax Planning for Multinational Borrowers During the COVID-19 Crisis

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With the likely increased borrowings or refinancing of debt as a result of the COVID-19 crisis, multinational companies should consider the impact of changes in U.S. tax law made in 2018. As a result of these changes, U.S....more

Hogan Lovells

Budget 2017

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The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more

Orrick, Herrington & Sutcliffe LLP

IRS and Treasury Issue Final Regulations Under §385 Classifying Interests in a Corporation

On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the “Final” or “Temporary” Regulations) under Internal Revenue Code section 385. These regulations, which consist of both temporary...more

Orrick, Herrington & Sutcliffe LLP

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity

On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more

Foley & Lardner LLP

Attention Taxpayers: New IRS Rules May Deem Debt to Be Stock

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In April, the IRS proposed rules that would treat debt between related corporations as stock for U.S. tax purposes. These rules would apply to all corporations (including regular C corporations, S corporations, foreign...more

Foley & Lardner LLP

IRS Rules Could Treat Related Party Debt as Stock

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Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more

Williams Mullen

Williams Mullen FDI USA Newsletter - June 2015

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- In this Issue: - Welcome - About Us - Results Of 2015 SelectUSA Summit - 2015 Upcoming Events - RAISING CAPITAL: Simplifying the U.S. Capital Markets - Recent FDI Success Stories - FDI...more

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