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Treasury Proposes Fundamental New Limitations on Related Party Lending Transactions - With Retroactive Effect!
  • Reed Smith LLP
  • USA
  • May 4 2016

The U.S. Treasury Department has very recently and unexpectedly released significant guidance that promises, if finalized, to fundamentally limit the

Section 385 Proposed Regulations
  • Fenwick & West LLP
  • USA
  • April 29 2016

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

New Proposed Regulations Increase Scrutiny on Related-Party Debt
  • Dechert LLP
  • USA
  • April 28 2016

The U.S. Treasury Department ("Treasury") and Internal Revenue Service ("IRS") recently issued proposed regulations (the "New Proposed Regulations"

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity
  • Orrick, Herrington & Sutcliffe LLP
  • April 28 2016

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity On April 4, 2016, the IRS and U.S. Treasury Department issued

Trade Alert - April 2016, Issue 28 - Ukraine
  • Cadwalader Wickersham & Taft LLP
  • Iceland, Ukraine, USA
  • April 28 2016

Ukraine is seeking to strengthen its ties with the EU, its largest trading partner. Ukraine’s main exports to the EU are raw materials, including iron

New tax rules treat related party debt as stock and impose strict documentation rules
  • Hogan Lovells
  • USA
  • April 15 2016

On April 4, the IRS and Treasury issued proposed regulations under section 385 of the Internal Revenue Code that treat related party debt as stock

Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership
  • Caplin & Drysdale, Chartered
  • USA
  • April 5 2016

In a statement issued on March 30th, the U.S. Treasury Department announced that it will soon be issuing proposed regulations that will require

Tax issues for repo buyers and sellers
  • Greenberg Traurig LLP
  • USA
  • November 2 2015

Near the beginning of the 1980s cult classic film "Repo Man," Harry Dean Stanton informs Emilio Estevez that the car which he just drove back to a

Funds talk: September 2015
  • Kramer Levin Naftalis & Frankel LLP
  • USA
  • September 1 2015

On Aug. 3, 2015, President Obama announced the Environmental Protection Agency’s (EPA) final Clean Power Plan rule, which will sharply cut emissions

Change-in-control compensation agreements : protecting the institution and your most important assets
  • Vorys, Sater, Seymour and Pease LLP
  • USA
  • July 29 2015

Imagine the following scenario: your bank has just announced an agreement to be acquired by a larger institution that is entering your market for