Consumer Finance Monitor Podcast Episode: Should Medical Debt Be Included in Creditworthiness Measures?
Credit Eco to Go Podcast: Demystifying the Debt Collection Rule
Law School Toolbox Podcast Episode 294: Money Talk (w/Carrie Friedberg)
Podcast: Questions & Concerns About Documentation: A Conversation with Colin Adams, M-III Partners
Podcast - Credit Funds: How PE Funds Can Address and Minimize Conflict When Expanding Into Credit
Underwriters, Universities and Government Debt Issuers Face a Critical Deadline
Maximizing Outcomes in Upcoming Asia Restructurings - Executive Summary
Bar President: 3Ls Should Get Paid for Internships
Bill on Bankruptcy: Kodak Plan Bumps the Debt, Craters Stock
Consultant: More Big Law Firms Will "Implode"
Law School Applications Crater
Will The Debt Ceiling Standoff End Up In Court?
Bill on Bankruptcy: MF Global Creditors Undeterred by Low Value
Symptoms of Student Loan Crisis Reveal Bubble About to Burst
Dean: There's No Oversupply of Lawyers
Bill on Bankruptcy: Will 2013 Be Kind To The Bankruptcy Bar?
The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more
What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more
Sometimes the first step to solving (or mitigating or avoiding) problems is to identify what the problem may be to, among other things, put time on one’s side. For issuers of tax-exempt municipal bonds, there tend to be...more
As reported late last year, the IRS announced in Notice 2022-1 (Notice) that lenders are not required to, and should not, issue IRS Forms 1099-C when certain student loan debts are forgiven. The Notice was in response to...more
According to a recent study, Americans currently owe approximately $1.4 trillion in student loan debt. With increasing pressure to pay off student loans, some employees choose not to contribute to retirement programs offered...more
The Internal Revenue Service (IRS) has issued a private letter ruling approving of an employer’s program to provide employees a retirement plan contribution conditioned on student loan repayments. Specifically, the IRS found...more
“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more
Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more
Issuers and their advisors need to be aware of the potential pitfalls and uncertainties of the applicable high-yield discount obligation rules, which can have the effect of permanently disallowing a portion of interest...more
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385. The final and temporary regulations recharacterize certain debt instruments as equity for...more
The recently released final regulations under Internal Revenue Code Section 385, addressing the circumstances under which related company debt will be classified as equity for federal income tax purposes, will have a...more
On April 4, 2016, the US Department of the Treasury and the Internal Revenue Service proposed regulations under section 385 of the Internal Revenue Code that would recharacterize certain related-party debt instruments, in...more
Determining the difference between debt and equity is a problem that has bedeviled taxpayers and tax administrators for decades. Taxpayers, recognizing that there are tax advantages to financing a corporation with debt (e.g.,...more
On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more
The rules of IRC § 1504 and Treas. Reg. § 1.1502-47 provide the general parameters for determining whether a domestic life insurance company (within the meaning of IRC § 816(a)) may join in filing a consolidated U.S. federal...more
Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more
On October 15, 2014, the Internal Revenue Service (IRS) and the Department of the Treasury proposed to remove the deemed 36-month non-payment testing period from the list of identifiable events that trigger the requirement to...more