News & Analysis as of

Tax Deductions Borrowers Internal Revenue Service

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

Lowenstein Sandler LLP

Paycheck Protection Program Round 2: FAQs For Microbusinesses

The Paycheck Protection Program closed on May 28, 2021. The SBA is no longer accepting new applications from participating lenders. The following FAQs are for informational purposes only and to assist borrowers who obtained...more

Payne & Fears

Paycheck Protection Program Phase 2: What Businesses Need to Know

Payne & Fears on

Much of the publicity and scrutiny surrounding the recently enacted coronavirus relief bill attached to the Consolidated Appropriations Act of 2021 has been focused on the economic impact payments and supplemental...more

Nossaman LLP

Congress Revises PPP Rules: Allows PPP Second Round, Reverses IRS Position on Deductibility

Nossaman LLP on

Congress has come bearing gifts this holiday season to those businesses hit hard by the ongoing COVID-19 crisis. On December 21, 2020, Congress passed the Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act...more

Ruder Ware

Paycheck Protection Program Loan Borrowers Will Find Deductions Under the Tree This Holiday Season

Ruder Ware on

On the evening of December 21, 2020 the House and Senate passed the Consolidated Appropriations Act, 2021 (the “Act”), a 5,593 page bill that funds the federal government for the next fiscal year and provides long anticipated...more

Nossaman LLP

On-Demand Webinar | PPP Loan Forgiveness: Employment and Tax Issues for Borrowers

Nossaman LLP on

Introducing Nossaman's Employment BUZZ webinar series! Each month, our attorneys will cover a different topic of interest to employers, including tax, insurance, intellectual property and employment issues. These "quick hit"...more

Hogan Lovells

Upstream guarantees and security by foreign subsidiaries of a U.S. corporate borrower may now be available without adverse U.S....

Hogan Lovells on

Tax structuring under the previous regime - Prior to the issuance of the final regulations described below, under Section 956 of the Internal Revenue Code of 1986 and its related Treasury Regulations, for U.S. tax...more

Proskauer Rose LLP

Newly Proposed US Tax Regulations Open Possibility of Full Credit Support from Foreign Subsidiaries

Proskauer Rose LLP on

On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code (the "Proposed Regulations") that are likely to enhance the availability of...more

Moore & Van Allen PLLC

Proposed Treasury Regulations Impact “Deemed Dividend” Tax Rules in Financing Transactions

Moore & Van Allen PLLC on

Following tax reform at the end of 2017, cash dividends from a foreign corporate subsidiary to a domestic corporate 10 percent shareholder are exempt from U.S. income tax because the shareholder is permitted a...more

Foster Garvey PC

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

Foster Garvey PC on

“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

10 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide