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U.S. Treasury Debt

Crunched Credit

James Carville Was Right:  It’s Good to be King - Life as the Puissant Bond Market

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Those Bond villains got it so wrong. All the time and energy they spent trying to control the world through complex and nefarious schemes involving laser beams, atom bombs, Fort Knox gold, exploding satellites and whatever...more

Tonkon Torp LLP

Governmental Structural Changes to the U.S. Economy Are Underway – What to Expect

Tonkon Torp LLP on

I attended the American Seniors Housing Association (ASHA) convention in Phoenix last month. The agenda featured an address by Rob Kaplan, Partner and Vice Chairman of Goldman Sachs, and former President and CEO of the...more

McGuireWoods Consulting

The Federal Debt Limit

The federal debt limit is not the same as funding the government. If the U.S. defaults on its debt, the ramifications are different than when Congress fails to fund the government. The recently released House Budget...more

Cooley LLP

Assessing the Impact of the Outbound Investment Security Program on Debt Transactions

Cooley LLP on

On January 2, 2025, the US Department of the Treasury implemented the new Outbound Investment Security Program (OISP), which prohibits or imposes notification requirements on certain investments by US persons in persons that...more

Proskauer - Tax Talks

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate Stock

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On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on...more

McDermott+

Healthcare Preview for the Week of: May 22, 2023

McDermott+ on

Debt Limit Deadline Draws Nigh - President Biden and House Speaker Kevin McCarthy are scheduled to meet one-on-one today, just 10 days ahead of the June 1 debt limit deadline....more

Paul Hastings LLP

Daily Financial Regulation Update -- Wednesday, August 3, 2022

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August 2, 2022- The U.S. Senate Committee on Banking, Housing, and Urban Affairs held a hearing entitled, "'The Rent Eats First': How Renters and Communities are Impacted by Today's Housing Market."...more

Fox Rothschild LLP

Defining Net Income For 2020 is Going To Be “A Problem”

Fox Rothschild LLP on

I attended a seminar offered by accountant, Mitchell E. Benson, CPA, MT, CFF (Savran Benson LLP), Brian C. Vertz, Esquire (Pollock Begg) and Aliah Molczan (Savran Benson LLP) on July 9, 2020. One of the topics discussed was...more

Foley & Lardner LLP

CARES Act – Federal Reserve Main Street Loan Facilities - Updated June 12, 2020

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The Main Street Lending Program, authorized under the CARES Act and Section 13(3) of the Federal Reserve Act, is designed to provide financial assistance to small and medium sized businesses. There will be three Main Street...more

McDermott Will & Emery

New Debt-Equity Regulations Address Certain Gaps, but More Guidance Is Expected

McDermott Will & Emery on

The final debt-equity regulations issued on May 13, 2020, finalize proposed section 385 regulations issued in 2016 without any substantive changes to the existing debt-equity regulations, and withdraw the temporary section...more

Herbert Smith Freehills Kramer

Debt-Equity Dashed Expectations: Treasury and the Service Retain Onerous Section 385 Regulations

On Nov. 4, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final debt-equity regulations (the Final Regulations) and an advance notice of proposed rulemaking (the...more

MoFo Reenforcement

Financial Services Report – Winter 2017

MoFo Reenforcement on

EDITOR’S NOTE - The holidays came early for the financial services industry. First, the Senate voted to repeal the CFPB’s rule banning class waivers in arbitration agreements in consumer financial contracts. Then,...more

Troutman Pepper Locke

New Temporary and Proposed Regulations Regarding Debt Allocations for Partnerships - 'Oh My' - Tax Update Volume 2017, Issue 1

Troutman Pepper Locke on

Although There Are Aspects of the Regulations that Practitioners and Taxpayers Still Disagree With, There Are Others that Are an Improvement on What Was Proposed Earlier. From 2013 through 2014, the IRS and the U.S....more

Orrick, Herrington & Sutcliffe LLP

IRS and Treasury Issue Final Regulations Under §385 Classifying Interests in a Corporation

On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the “Final” or “Temporary” Regulations) under Internal Revenue Code section 385. These regulations, which consist of both temporary...more

Alston & Bird

Stock Acquisitions Checklist

Alston & Bird on

On October 22, 2016, the Treasury finalized the debt/equity regulations under Section 385 it had proposed in April. The 517-page package can daunt even the most motivated readers. “Expanded groups” (EG) that know they will be...more

Proskauer Rose LLP

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

Proskauer Rose LLP on

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385. The final and temporary regulations recharacterize certain debt instruments as equity for...more

BakerHostetler

Final and Temporary Debt-Equity Regulations Under Section 385 Implement Highly Favorable Changes

BakerHostetler on

On Oct. 13, 2016, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final and temporary regulations under Section 385 governing the treatment of certain instruments as debt or equity...more

Orrick, Herrington & Sutcliffe LLP

Tax Benefit from Leveraged Partnerships Shut Down By New IRS Regulations

On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more

McDermott Will & Emery

SALT Implications of Proposed Section 385 Debt/Equity Regulations

McDermott Will & Emery on

Determining the difference between debt and equity is a problem that has bedeviled taxpayers and tax administrators for decades. Taxpayers, recognizing that there are tax advantages to financing a corporation with debt (e.g.,...more

BCLP

That Debt Isn’t What You Think It Is: New Proposed Debt/Equity Rules Could Be Biggest Change in Corporate Tax Since 1986

BCLP on

The U.S. Treasury Department issued new proposed tax regulations that would re-characterize certain related party debt as equity, resulting in dividend payments rather than tax deductible interest payments. If finalized in...more

Bilzin Sumberg

Proposed Section 385 Regulations May Dramatically Impact Portfolio Debt Planning

Bilzin Sumberg on

On April 4, 2016, the IRS and Treasury issued proposed regulations under Section 385 (the “Proposed Regulations“). The Proposed Regulations, which were thought to have been a response to post-inversion earnings stripping...more

Baker Donelson

New "Inversion" Proposed Regulations Inspired By The Pfizer/Allergan Deal May Impact Corporate Tax Planning Strategies

Baker Donelson on

The Treasury Department has recently promulgated proposed regulations dealing with so-called inversion transactions. Inversion transactions are ones in which a U.S. corporation changes its domicile to a nation with a more...more

Fenwick & West LLP

Section 385 Proposed Regulations

Fenwick & West LLP on

On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code. Issued the same day as the anti-inversion temporary regulations, the proposed § 385 rules would go much farther than merely...more

Foley & Lardner LLP

IRS Rules Could Treat Related Party Debt as Stock

Foley & Lardner LLP on

Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more

Eversheds Sutherland (US) LLP

Only the Lonely: “Lonely” Life Insurance Companies Confront New Issues Under Proposed Debt-Equity Regulations

The rules of IRC § 1504 and Treas. Reg. § 1.1502-47 provide the general parameters for determining whether a domestic life insurance company (within the meaning of IRC § 816(a)) may join in filing a consolidated U.S. federal...more

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