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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

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

Cadwalader, Wickersham & Taft LLP

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

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

Mayer Brown on

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?

Rivkin Radler LLP on

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

Akin Gump Strauss Hauer & Feld LLP

Could Future COVID-19 Relief Allow COD Income Deferral?

The Coronavirus Aid, Relief and Economic Security Act (CARES Act) (P.L. 116-136), signed into law March 27, contained numerous business relief provisions, one of which was a repeat from the 2008-2009 financial crisis. While...more

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