News & Analysis as of

Loans Income Taxes

Kelley Drye & Warren LLP

Proposed Section 899 - The Retaliatory Tax Regime

The One Big Beautiful Bill Act (the ​“Bill”), which was passed by the House of Representatives on May 22, 2025, contains a provision that, if enacted in its current form, would have a dramatic impact on the U.S. tax treatment...more

Rivkin Radler LLP

Writing Off A Loan – Simultaneous COD Income and Bad Debt Deduction? Not Necessarily

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If you’ve been around closely held businesses long enough, you know that a transfer of money between a business and its owner, or between two related businesses, is sometimes characterized by the parties as a loan (“related...more

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

Warner Norcross + Judd

The Powers and Perils of Intrafamily Loans

It is not uncommon for family members to lend a helping hand to one another through intrafamily loans. While loans can benefit family borrowers who may not qualify for a traditional loan or who need flexible payment...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

Pillsbury Winthrop Shaw Pittman LLP

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

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

Cadwalader, Wickersham & Taft LLP

Reap What You Sow – UK’s Unallowable Purpose Rule Considered Again

In Syngenta Holding Limited v HMRC [2024] UKFTT 998 (TC) (“Syngenta”), the UK’s First-tier Tribunal (“FTT”) denied a deduction for interest on an intra-group loan on the basis that the loan had an unallowable purpose for the...more

Proskauer Rose LLP

UK Tax Round Up - April 2024

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Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing...more

McDermott Will & Schulte

Weekly IRS Roundup March 25 – March 29, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 25, 2024 – March 29, 2024....more

Proskauer Rose LLP

UK Tax Round Up - March 2023

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Welcome to February’s edition of our UK Tax Round Up. The month has seen interesting cases on the “entitlement” to income and the single and multiple supply tests for VAT as well as announcement of the publication date for...more

Rivkin Radler LLP

Generating Tax Losses as a Hobby

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Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more

Rivkin Radler LLP

Biden’s Proposed Income Tax Increases And The Sale Of The Baby Boomer Business

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“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more

Bowditch & Dewey

2020 End of Year Tax Planning for Individuals

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As the 2020 year draws to a close, families should review with their tax advisers the CARES Act tax-related provisions in their tax and financial planning. Tax provisions that apply to individuals include the following: ...more

Gerald Nowotny - Law Office of Gerald R....

THE WONDER YEARS WEBINAR

Loan Regime Method of Split Dollar Life Insurance - This webinar covers: What is Split Dollar? Loan Method versus Economic Benefit. Leverage Split Dollar Rollout. Planning examples using Split Dollar....more

Gerald Nowotny - Law Office of Gerald R....

HEAVEN CAN WAIT

Nowotny On Death and Taxes podcast episode #24, discusses using the Loan Method of Split Dollar in the After-Life!...more

Bowditch & Dewey

Can I Withdraw Funds From My Retirement Account During COVID-19?

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The Paycheck Protection Program money is spent, the temporary $600 weekly unemployment supplement is over, and we still need money. We could draw on our savings, sell investments, or take out a loan against our home. Usually,...more

Foley & Lardner LLP

IRS Provides Additional Guidance for CARES Act Retirement Plan Loans and Distributions

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On June 19, 2020, the IRS issued Notice 2020-50 (the “Notice”), which provides additional guidance regarding coronavirus distributions and loans from qualified retirement plans under the Coronavirus Aid, Relief, and Economic...more

Farrell Fritz, P.C.

Business Resources and Recovery (UPDATED)

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Businesses grappling with the economic impact of the ongoing COVID-19 crisis have the opportunity to apply for financial assistance through a variety of Federal, State and Local programs. ...more

Farrell Fritz, P.C.

Recapitalizing Debt To Defer Payment Of The Estate Tax – Good Idea?

Farrell Fritz, P.C. on

Estate Planning 101- A basic precept of effective estate planning is for a member of an older generation to transfer[i] property to a family member of a younger generation – for example, stock in a closely held corporation...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Old loans can come back to bite you in an audit

There is nothing wrong with offering loans with your 401(k) plan. What will be wrong is if the program isn’t administered properly and you don’t have the backup to prove you administered it correctly....more

Verrill

Recap of Change to Retirement Plan Rollover Rules for Plan Loan Offsets

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The Tax Cuts and Jobs Act of 2017 (“2017 Tax Act”) includes a provision that changed the rollover rules for certain plan loan offset distributions and that may not be well known to retirement plan sponsors and participants. ...more

White & Case LLP

New Tax Rates Applicable to Bond and Sukuk Income, Tier II loans and securitizations

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Withholding tax rates on income derived from Eurobonds and lease certificates issued outside of Turkey, on interest payments of Tier II loans and securitization financings; as well as BITT applicable to securitizations backed...more

Holland & Knight LLP

Tax Reform's Impact on 401(k) Plan Loan Offset Treatment - Actions for Plan Administrators and Human Resources Benefits Managers

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• The recent Tax Cuts and Jobs Act of 2017 (the Act), enacted on Dec. 22, 2017, contains a few rules that will impact benefit administrators. • This client alert focuses on changes made to the tax treatment of plan loan...more

Hogan Lovells

Draft tax legislation for 2017 released

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Following the 2017 Budget presented before Parliament on 22 February 2017, the draft tax legislation for the specific tax proposals was released on 19 July 2017 for comment. Comments should be made by 18 August 2017. ...more

Bradley Arant Boult Cummings LLP

Intra-Family Loans: An Estate Planning Strategy in a Low-Interest Rate Environment

In the current economic environment, IRS-prescribed monthly interest rates for certain intra-family transactions are at historic lows. As a result, an excellent opportunity exists to transfer wealth to lower generation family...more

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