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Financial Institutions › Internal Revenue Code (IRC) › Income Taxes

Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

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In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Makes Permanent Its Fast-Track Corporate Private Letter Rulings

Skadden, Arps, Slate, Meagher & Flom LLP on

On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more

Hogan Lovells

With a New Year, Brings a New Rate . . . The Transition from LIBOR Is Now Here

Hogan Lovells on

In March 2021, the Financial Conduct Authority (FCA) and the ICE Benchmark Administration, the administrator of LIBOR, announced that sterling, euro, Swiss franc and Japanese yen LIBOR panels, as well as panels for one-week...more

Bradley Arant Boult Cummings LLP

ADOR Affirms Deductibility of PPP Loan-Related Expenses but Unanswered Conformity Questions Remain

Bradley Arant Boult Cummings LLP on

The Alabama Department of Revenue issued helpful guidance on January 7, following its December 18, 2020 guidance implementing Governor Ivey’s landmark Supplemental Emergency Proclamation. The new guidance affirms the...more

Bradley Arant Boult Cummings LLP

COST Weighs-In on Alabama DOR’s Analysis of Federal Tax Reform - SALT Alert: Alabama Edition

Bradley Arant Boult Cummings LLP on

On July 31, the Alabama Department of Revenue (ADOR or Department) released its long-awaited and quite comprehensive analysis of the impact of the Tax Cuts and Jobs Act of 2017 (otherwise known as “federal tax reform”) on...more

McDermott Will & Schulte

SALT Implications of Final Section 385 Debt-Equity Regulations

McDermott Will & Schulte on

The recently released final regulations under Internal Revenue Code Section 385, addressing the circumstances under which related company debt will be classified as equity for federal income tax purposes, will have a...more

Baker Donelson

Spotlight On Alabama: A Busy Tax Year in Review

Baker Donelson on

It has been a busy year for developments in Alabama state taxation. In this tax alert we review many of the significant developments that have occurred over the last 12 months....more

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