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
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