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Loans Tax Planning

Loeb & Loeb LLP

Key Legal and Market Trends in Private Client Finance

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Anthony Pirraglia, deputy chair of the firm’s Finance department, shares insight into how legal and regulatory trends are shaping private client finance today. As loans to ultra high net worth individuals and their controlled...more

Fox Rothschild LLP

How to Capitalize on the Auto Loan Tax Deduction in the One Big Beautiful Bill

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The automotive industry has been abuzz with talk of the auto loan interest deduction included in the One Big Beautiful Bill — the sweeping federal tax and spending plan that was signed into law on July 4 by President Trump. ...more

Burr & Forman

Georgia House Bill 586 Expands Loan Flexibility and Tax Exemptions

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On May 9, 2025, Governor Brian Kemp signed into law House Bill 586, which significantly amends Georgia’s intangible recording tax provisions. Effective July 1, 2025, the bill extends the maturity threshold for “short-term...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

A&O Shearman

Navigating private credit in Türkiye

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Türkiye is fast emerging as an increasingly attractive destination for private credit providers looking to deploy capital and diversify their portfolios. Despite this growing interest, relative to its size as the seventh...more

Bressler, Amery & Ross, P.C.

How to Take Advantage of Changes in Interest Rates For Gift and Estate Tax Savings

A recent Tax Court order highlights the gift and estate planning opportunities afforded when a senior family member makes loans to other family members. In Galli v. Commissioner, Docket Nos. 7003-20 and 7005-20, the Court had...more

Rivkin Radler LLP

“Hey Mom, Can I Have A Few Bucks?” Is It A Loan? A Gift? A Little of Each?

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A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own. For example, the child may have identified an attractive business opportunity...more

Mayer Brown

Déductibilité des intérêts portant sur les obligations convertibles : validation de l'utilisation du logiciel Standard et Poor's...

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Par un arrêt du 28 janvier 2025, le Tribunal administratif de Cergy Pontoise (n°2100034) approuve l'utilisation du logiciel Standard et Poor's Capital IQ pour justifier le taux d'intérêt d'obligations convertibles....more

Rivkin Radler LLP

Business Owner Borrows from Their Private Foundation – A Different Form of “For Profit Philanthropy”?

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Many successful business owners attribute some part of their success to their community. For some of these owners, it is not enough to simply acknowledge this “debt”; they feel an obligation to share some of their financial...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

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

WilmerHale

Commonly Considered Option Program Enhancements: Part IV - Employee Loans To Purchase Shares

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Consider this fairly typical situation. Four years ago, employee Emma was granted an incentive stock option (ISO) to purchase 100,000 shares with an exercise price of $0.86 per share. Emma’s award is fully-vested and she...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

Latham & Watkins LLP

Navigating Debt Repurchases in Europe: What You Need to Know - October 2022 #2

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This Client Alert examines the key issues that typically arise in connection with debt repurchase programs. It also looks at issues applicable to both bond and loan repurchases, as well as jurisdictional issues raised by the...more

Pullman & Comley, LLC

Manufacturing Updates - Fall 2021

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Welcome to Manufacturing Updates, Pullman & Comley’s quarterly publication that summarizes important legal developments for manufacturers. Manufacturing Updates brings together insights from attorneys across our many practice...more

Hogan Lovells

Luxembourg is modernising its securitisation law

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The Luxembourg law on securitisation dated 22 March 2004 (the “Securitisation Law”) has been tremendously successful in providing a flexible and secure framework for Luxembourg securitisation vehicles (“SVs”), attracting a...more

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

RETURN TO FOREVER: What Game Should We Play Today? Using the Planning Power of Split Dollar Life Insurance for Income and Estate...

This article focuses on the use of Split Dollar life insurance and the use of the Leveraged Split Dollar RolloutTM technique combining the tax arbitrage of life insurance with the financial arbitrage of Split Dollar life...more

Polsinelli

IRS Ruling Takes Aim at Impact Investing

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What many in the nonprofit community would have expected to be a direct road for tax exemption for a new 501(c)(3) nonprofit organization has suffered a significant set-back. On October 9th, the Internal Revenue Service...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

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

THE WONDER YEARS WEBINAR - LOAN REGIME METHOD OF SPLIT DOLLAR LIFE INSURANCE

In this webinar you will find the answers to these important questions: 1) Why is the Loan Method of Split Dollar an important planning technique right now? 2) What is the financial and tax leverage of Loan Method Split...more

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

THE WAY WE WERE

Using the Loan Method of Split Dollar to recreate the benefit of tax deferral for Hedge Fund Managers in lieu of carried interest in their offshore fund.#splitdollar #ppli #estateplanning #financialadvisors #finance...more

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

THE WAY WE WERE

Nowotny On Death and Taxes, episode #20, The Way We Were is about using the Loan Method of Split Dollar to recreate the benefit of tax deferral for hedge fund managers. #splitdollar #ppli #hedgefundmanagers #estateplanning...more

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

THE WAY WE WERE - Using Loan Method Split Dollar to Recreate the Benefit of Tax Deferral for Carried Interest

Hedge Fund managers previously had an unprecedented ability to defer their carried interest in the offshore hedge funds that they manage. IRC Sec. 409A put an end to those deferrals and required hedge fund managers to...more

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