THE SPLIT DOLLARMINATOR!
Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more
In a decision rendered September 8, 2022, a three-judge panel for the United States Court of Appeals for the Second Circuit (the “Court”) vacated a February, 2021 decision by the United States District Court for the Southern...more
Summary of Case - On August 11, 2020, the administrative agent in a loan to Revlon intended to make an interest payment to the lender syndicate and instead mistakenly wired almost $900 million of its own money to the...more
The abrupt halt in commercial activity caused by the 2019 Novel Coronavirus (“COVID-19”) has had a significant impact on the global economy, and in particular, the commercial real estate market. As a result, the commercial...more
Congratulations! Your startup has developed a viable product that you are ready to test in the market. But you need some early money to fund this critical phase! Convertible debt can allow a startup to raise money with more...more