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IRS Issues Carried Interest Guidance

On July 31, 2020, the Internal Revenue Service and the U.S. Treasury Department issued Proposed Treasury Regulations (the “Proposed Regs”) providing guidance under the “carried interest” rules of Section 1061 of the Internal...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – “C” Corporation Considerations Supplement

The discussion in this Quick Study Supplement outlines select federal income tax issues “C” corporation borrowers may face in debt restructurings. As noted in our debt restructuring overview Quick Study, a borrower generally...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – Lender Considerations Supplement

Distressed economic climates can produce unique circumstances for a lender. As a borrower defaults on payments or breaches financial covenants, a lender may reexamine its tax reporting around the borrower’s debt (e.g.,...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – Partnership Considerations Supplement

The discussion in this Quick Study Supplement outlines select federal income tax issues partnership borrowers may face in debt restructurings. As noted in our debt restructuring overview Quick Study, a borrower generally...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – “S” Corporation Considerations Supplement

The discussion in this Quick Study Supplement outlines select federal income tax issues “S” corporation borrowers may face in debt restructurings.1 As noted in our debt restructuring overview Quick Study, a borrower generally...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn

As the economic impact of COVID-19 continues to evolve, many businesses are looking to restructure their debt to help navigate through the crisis. In the past several weeks, lenders have been inundated with such requests,...more

IRS Issues Final Regulations under Section 956, With Few Changes from Proposed Regulations

Following its issuance of proposed regulations in November of last year, the IRS today published final regulations (84 FR 23716) under Section 956 of the Internal Revenue Code. The final regulations include very few changes...more

IRS Issues Proposed Regulations under Section 956, Potentially Impacting Certain Multinational Debt Structures

The IRS recently issued proposed regulations (REG-114540-18) under Section 956 of the Internal Revenue Code limiting the effect of such section, and potentially impacting relatively standard collateral package provisions for...more

New Tax Law May Reduce Tax Benefit for Cross-Border Affiliated Insurance/Reinsurance Premiums

On December 22, 2017, the President signed into law H.R. 1, known generally as the Tax Cuts and Jobs Act (the “TCJA”), which makes widespread changes to the Internal Revenue Code. The TCJA includes a number of provisions that...more

Captive Insurance Arrangements Taking Advantage of Section 831(b) Election May Be Required to Report to the IRS

The Internal Revenue Service on November 1, 2016 issued Notice 2016-66 (the Notice) requiring information reporting with respect to certain insurance or reinsurance transactions (often referred to as micro-captive...more

Rhode Island Proposes Innovative Approach to Reduce Premium Tax Rate

Parallel bills proposing to reduce the current two-percent Rhode Island insurance premium tax are before both the Rhode Island House and Senate. Working with the Rhode Island Department of Business Regulation, Representative...more

New York State Clarifies Taxation of Unauthorized Insurance Companies

Three recent decisions (March 3, 2016) by a New York State Division of Tax Appeals administrative law judge help to clarify the taxation of unauthorized insurance companies subject to New York State taxation. New York...more

Congress Expands and Tightens Section 831(b) Small Insurance Company Election

On December 18, 2015, Congress enacted the Protecting Americans from Tax Hikes Act of 2015, making, among other items, several significant changes to the provisions of Internal Revenue Code Section 831(b), which provides...more

Insurance Newsletter September 2015

On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a District Court decision and ruled that the Internal Revenue Service could not impose excise tax on certain wholly-foreign retrocessions...more

Validus Round Two: Court of Appeals’ Decision Holding That Wholly-Foreign Retrocessions Are Not Subject to Federal Excise Tax...

On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a District Court decision and ruled that the Internal Revenue Service could not impose excise tax on certain wholly-foreign retrocessions...more

Locke Lord QuickStudy: Validus Court of Appeals Decision - Wholly-Foreign Retrocessions Not Subject to Federal Excise Tax

On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a District Court decision and ruled that the Internal Revenue Service could not impose excise tax on certain wholly-foreign retrocessions...more

Validus Wins Round Two: Wholly-Foreign Retrocessions Not Subject to Federal Excise Tax

On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a lower court decision and ruled that the IRS could not impose excise tax on certain wholly-foreign retrocessions of insurance. The...more

Locke Lord QuickStudy: Proposed Regulations Issued On Hedge Fund Reinsurance Transactions

The Internal Revenue Service (IRS) recently issued proposed regulations addressing what constitutes the “active conduct of an insurance business” for purposes of the passive foreign investment company (PFIC) rules (the...more

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