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IRS memorandum finds loans to U.S. borrowers by foreign lender with U.S. agent are subject to U.S. taxation

Katten Muchin Rosenman LLP
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USA
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September 24 2009

The Associate Chief Counsel (International) of the IRS has issued a memorandum in which it concludes that a foreign corporation (“LoanCo”) is engaged in a U.S. trade or business and subject to U.S. taxation on its net income from loans made by LoanCo to U.S. borrowers under the following circumstances

IRS guidance addresses theft loss deduction for investors in Ponzi schemes

Katten Muchin Rosenman LLP
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USA
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March 20 2009

The IRS has issued guidance clarifying the tax law rules relating to theft loss deductions and providing a “safe harbor” for U.S. investors who suffered losses from investments in Ponzi schemes to claim a theft loss deduction

Stimulus bill allows deferral of COD income realized from repurchases of debt at a discount

Katten Muchin Rosenman LLP
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USA
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March 18 2009

The current debt market environment may offer opportunities for borrowers to purchase their debt at a discount

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IRS memorandum finds loans to U.S. borrowers by foreign lender with U.S. agent are subject to U.S. taxation

IRS guidance addresses theft loss deduction for investors in Ponzi schemes

Stimulus bill allows deferral of COD income realized from repurchases of debt at a discount

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