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Final Section 956 Regulations Open the Door to Foreign Credit Support for US Corporate Borrowers

Section 956 final regulations confirm those eligible for territorial dividend exemption can benefit from foreign guarantee and collateral support without incurring US tax. On May 23, 2019, the US Treasury and Internal...more

US Tax Reform: Opportunities and Challenges for Leveraged Finance

The new tax rules are expected to have an immediate impact on leveraged companies and leveraged finance transactions. On December 22, 2017, President Trump signed into law the “Tax Cuts and Jobs Act” (the Act).1 This...more

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