News & Analysis as of

Tax Planning Lenders

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

Mayer Brown

Subscription Finance: Cascading Pledges

Mayer Brown on

Cascading pledges are frequently used in subscription finance to avoid legal impediments, avoid tax implications and mitigate prohibited transaction risk under the Employee Retirement Income Security Act of 1974, as amended...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

Levenfeld Pearlstein, LLC

Independent Sponsor Update: Key Takeaways from Q1

The year is off to a busy start for us: In addition to deal work and portfolio company matters, our team attended conferences and met with various capital providers, independent sponsors, placement agents, and service...more

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

To Be or Not to Be Contemplating the Meaning of Life Through Private Placement Life Insurance

The focus of this article illustrates why private placement life insurance (“PPLI”) is the best asset to utilize in the “Buy, Borrow and Die” strategy for high net worth investors including billionaires. After this article,...more

Mayer Brown

Subscription Credit Facilities: Understanding Shared Blockers

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EXECUTIVE SUMMARY - Private equity structures often use “blockers” to achieve certain tax benefits. In this Legal Update, we explain what blockers are, how they may be used in a subscription credit facility, and what...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

A&O Shearman

Carbon Capture, Use, and Sequestration (CCUS) Webinar

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This webinar featured a case study approach to a CCUS project to identify the key commercial arrangements and risk pressure points that sponsors, tax equity and cash equity investors, and lenders evaluate in connection with...more

A&O Shearman

[Webinar] Carbon Capture, Use, and Sequestration (CCUS) - May 12th, 11:00 am ET

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This webinar uses a case study approach to a CCUS project to identify the key commercial arrangements and risk pressure points that sponsors, tax equity and cash equity investors, and lenders evaluate in connection with...more

McGlinchey Stafford

[Webinar] Updates to the Paycheck Protection Program & Other Issues - March 18th, 2:00 pm ET

McGlinchey Stafford on

Join us on Thursday, March 18 for the second installment in our 3-Part webinar series on the Paycheck Protection Program and formulate your game-plan before you apply for forgiveness. McGlinchey attorneys Richard Aguilar,...more

Hogan Lovells

Important changes to DAC6 regime in the UK: impact on bank lending transactions

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The UK has made important changes to its implementation of the EU Mandatory Tax Disclosure Rules known as DAC6. The changes, which significantly reduce the scope of the rules in the UK ...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

McDermott Will & Schulte

[Webinar] Navigating PPP Loan Forgiveness (Part 2) - August 20th, 3:00 pm - 4:00 pm EDT

Join McDermott and BDO on Thursday, August 20 to hear about the latest updates concerning the Paycheck Protection Program (PPP). Our multi-disciplinary panel will cover the most pressing issues as of August 2020, including: ...more

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

Mad Dogs and Panameños!

Using the Leveraged Split Dollar Rollout (LSD™ Rollout) to Terminate Loan Regime Split Dollar™ Plans Leveraged Split Dollar - low interest rate loans, tax advantage build up of life insurance policy, and a great technique to...more

Best Best & Krieger LLP

Best in Law: Take Some Time with Your Minute Book

BB&K Business Attorney Brian Reider Discusses the Importance of Minute Books in the Southern California Newspaper Group - Looking back at the year, one recurring theme emerges with corporate clients and their...more

Herbert Smith Freehills Kramer

IRS Paves the Way for Lenders to Obtain Guarantees and Collateral From (and 100% Stock Pledges of) Foreign Subsidiaries

Background On Oct. 31, 2018, the Internal Revenue Service issued proposed regulations under Section 956 of the Internal Revenue Code that will eliminate the adverse tax consequences when a U.S. parent corporation (i)...more

Foster Garvey PC

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

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“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

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