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Lenders › Borrowers › Income Taxes

Cadwalader, Wickersham & Taft LLP

Quarter End Fireworks, June 2025 - In the News: (Potentially) Taking Revenge Through Tax

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As we power through what remains of this quarter, working to get deals closed before quarter end next week, you may have noticed some additional (and new!) blacklining in the tax section of your credit agreement thanks to a...more

Troutman Pepper Locke

The Big Beautiful Bill and the Effects on Bank Lending Into the US

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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

Allen Matkins

LA Wildfires Client Resources

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Allen Matkins takes great pride in our California roots and strong ties to the Los Angeles community, and we are profoundly saddened by the devastation caused by the wildfires in our state. We are deeply committed to...more

Cadwalader, Wickersham & Taft LLP

An option to dispose of property does not necessarily give rise to a taxable disposal

Cadwalader, Wickersham & Taft LLP on

In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more

Mayer Brown

Exploring the Unexpected and Often Unwelcome Federal Income Tax Consequences of Debt Modifications

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As a number of debt instruments issued several years ago in a relatively low interest rate environment now have their maturity date approaching in a much higher interest rate environment, borrowers are increasingly seeking to...more

Rivkin Radler LLP

Selling Your Business? Take the Money But Defer the Tax?

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Sale of the Business- Imagine Client has just received an attractive, all cash offer for the sale of their business; there is no financing contingency. The buyer has proposed a cash-free and debt-free deal....more

McGlinchey Stafford

1099-C Discharge Without Debt Cancellation Not Consumer Protection Law Violation

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Once again, a borrower who argued his debt was cancelled when he received an IRS Form 1099-C was told by the court that it was merely discharged. The court says “discharge” is not “actual discharge.” While acknowledging that...more

McGlinchey Stafford

When Is Form 1099-C Required of Lenders? [More with McGlinchey, Ep. 16]

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When debt is forgiven, as much of the funding lent through the CARES Act’s PPP may be, a lender may be required to file IRS Form 1099-C with the IRS and to furnish a copy to the borrower. As a lender, do I need to file the...more

Pillsbury Winthrop Shaw Pittman LLP

Distressed Real Estate During the COVID-19 Pandemic: Deeds in Lieu of Foreclosure Involving Commercial Real Estate

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In a deed in lieu of foreclosure, a defaulting borrower agrees to convey the mortgaged property to the mortgage lender. But handing over the keys can raise a number of potential pitfalls. Below, we discuss some of these...more

Troutman Pepper Locke

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – Lender Considerations Supplement

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Distressed economic climates can produce unique circumstances for a lender. As a borrower defaults on payments or breaches financial covenants, a lender may reexamine its tax reporting around the borrower’s debt (e.g.,...more

Proskauer Rose LLP

UK Tax Round Up - June 2018

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Streaming of losses on trade succession (Leekes v. HMRC) - This case involved a taxpayer who purchased a business (the "predecessor business") and combined it with their existing business (creating the "enlarged...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

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“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

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