With the dire economic contractions occasioned by the rapid spread of COVID-19 nationally and globally, many businesses are quickly running short of capital to make payroll, pay rent, cover other critical overhead and remain...more
In an April 9, 2020, press release, the Federal Reserve (the “Fed”) announced additional actions to provide up to $2.3 trillion in loans to support the economy. The Fed’s stated goal is to “assist households and employers of...more
Recently proposed IRS regulations materially change the way stock and assets of foreign corporations that are “controlled foreign corporations” (CFCs) can be used to support debt of U.S. affiliates. ...more