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Loans Income Taxes Tax Liability

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

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

Troutman Pepper Locke on

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 - March 2023

Proskauer Rose LLP on

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

Farrell Fritz, P.C.

Business Resources and Recovery (UPDATED)

Farrell Fritz, P.C. on

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

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