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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

Seward & Kissel LLP

FinCEN Proposes New Rule to Subject Advisers to AML Requirements

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Who may be interested: Investment Advisers; Closed-End Funds; and Directors of Closed-End Funds - Quick Take: The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued a notice of...more

Cadwalader, Wickersham & Taft LLP

A Worthwhile Proposal for Worthless Debt

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In December, Treasury and the IRS issued proposed regulations updating the standard for determining when a debt instrument held by certain banks and insurance regulated entities will be conclusively presumed to be worthless...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

Goodwin

U.S. Department of Labor Formalizes Reinstatement of “Five Part Test” For Fiduciary Investment Advice and Proposes Broad Principal...

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On June 29, 2020, the U.S. Department of Labor (the Department) formally reinstated its “five-part test” for determining what constitutes “investment advice” under ERISA and Section 4975 of the Internal Revenue Code (the...more

Katten Muchin Rosenman LLP

The Code to the Rescue! Leveraging the Internal Revenue Code to Help Employees During the COVID-19 Crisis

Katten Muchin Rosenman LLP on

As we find ourselves in the midst of a national medical and financial crisis, employers are asking what they can do to help employees, and how they can do it in a way that costs less money. Although the President just signed...more

Ballard Spahr LLP

2016 Year End Review: Virtual Currency: DOJ and IRS Broadly Seek Virtual Currency Account User Information

Ballard Spahr LLP on

Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more

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