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Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Proskauer - Tax Talks

Senator Tillis Introduced a Bill Taxing Proceeds of Litigation Financing Agreements

Proskauer - Tax Talks on

Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill...more

Pillsbury Winthrop Shaw Pittman LLP

Norwich v. Comm’r: Private Credit Firm Prevails in Tax Dispute to Reverse Over-Reported Income

Pillsbury Winthrop Shaw Pittman LLP on

In Norwich v. Comm’r, the taxpayer mistakenly received $7.5 million[2] as a result of various bank errors between 2007 and 2014. Not knowing that the cash was incorrectly released to it, the taxpayer reported those amounts as...more

Womble Bond Dickinson

Micro-captive Insurance Reportable Transactions and the Reporting Requirements

Womble Bond Dickinson on

Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

Levenfeld Pearlstein, LLC on

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Cadwalader, Wickersham & Taft LLP

Treasury Cries “Uncle” to Crypto Industry: Crypto Reporting Delayed

Cadwalader, Wickersham & Taft LLP on

On January 16th, the IRS published Announcement 2024-4 (the “Announcement”), postponing certain reporting requirements for large crypto transactions which were set to go into effect for the 2024 tax year.  Persons engaged in...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

Morgan Lewis

Sovereign Wealth Funds Update: Tax Aspects of Private Fund Investments: Selected US, EU, and UK Considerations in the Current...

Morgan Lewis on

Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more

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