THE SPLIT DOLLARMINATOR!
You may have heard recently about proposals for Congress to remove the exclusion from gross income of interest on state and local bonds, usually referred to as “repealing the tax exemption on municipal bonds.” This issue...more
In the current world, where trade ties are vital in strengthening the economy of a country, it is often necessary to enter into legal contracts with various entities around the world. It is also necessary that these contracts...more
Recently, in Exxon Mobil Corp. v. United States (No. 3:22-cv-00515), a District Court in Texas ruled that the taxpayer was entitled to interest deductions on a production loan entered into as part of a multibillion-dollar...more
Among other tax incentives for individual and corporations, the Luxembourg Parliament adopted on 11 December 2024 an amendment to the interest deduction limitation rule via the introduction of the concept of a single-entity...more
On 1 April 2022, the UK introduced a new tax advantaged corporate structure, a "qualifying asset holding company" ("QAHC"), which benefits from a number of UK tax breaks. A crucial requirement for QAHC eligibility is that...more
The Court of Appeal's recent judgment in Topalsson v Rolls-Royce looks at how the set-off of counterclaims should be addressed as well as interest when it comes to liability caps....more
The issue before the Supreme Court in Cantero v. Bank of America was straightforward: does the National Bank Act preempt a New York state law requiring all banks, including national banks, to pay interest on certain mortgage...more
The treatment of contingent interest and convertible debt in cross-border payment transactions is subject to several provisions of the Internal Revenue Code. To add confusion to the already complicated subject, the...more
It was a muted start to the year for the acquisition and leveraged finance market due to a challenging macroeconomic climate. Interest rate hikes at one of the fastest paces on record, surging inflation (particularly in...more
The U.S. Supreme Court recently granted certiorari to hear the Second Circuit case of Cantero et al. v. Bank of America, N.A., involving National Bank Act (NBA) preemption of New York’s law requiring that interest be paid to...more
Q: In a receivership I just wrapped up, the court approved by final account and report and awarded me final fees. Because there were insufficient funds in estate to pay my fees in full, the court ordered the defendant to pay...more
Welcome to February’s edition of our UK Tax Round Up. The month has seen interesting cases on the “entitlement” to income and the single and multiple supply tests for VAT as well as announcement of the publication date for...more
In Cantero vs. Bank of America, N.A., mortgage borrowers are asking the Supreme Court of the United States to reverse a Second Circuit ruling that federally-chartered banks need not comply with state laws that require the...more
Like Zeus unleashing the Kraken in Clash of the Titans, the U.S. Securities and Exchange Commission (SEC) has unleashed the Kraken (not the digital asset company) to unleash havoc on Genesis Global Capital LLC (Genesis) and...more
Court rules that Earn Account Cryptocurrency is owned by Debtors and will not be returned - In our latest Bitblog update regarding the Celsius Network LLC, et al. (the “Debtors”) bankruptcy proceeding (Case No. Number:...more
The “crypto winter” of 2022 brought a bear market and a recent wave of bankruptcies to the crypto industry, leaving some retail customers of crypto exchanges frozen out of their accounts. As the bankruptcy filings mounted...more
One can hardly miss the high levels of inflation currently affecting our economy. Even for those who do not pay close attention to the news, where inflation could hardly be more covered, the price of nearly everything for...more
In a decision rendered September 8, 2022, a three-judge panel for the United States Court of Appeals for the Second Circuit (the “Court”) vacated a February, 2021 decision by the United States District Court for the Southern...more
Over the past several years as Collateralized Loan Obligations (“CLOs”) reached new and dizzying heights in issuance volume, CFOs have been quietly, and under the radar, gaining market acceptance and momentum among asset...more
The California State Legislature has passed legislation giving the Controller the green light to establish a California Voluntary Compliance Program (VCP) for holders of unclaimed property. The bill, A.B. 2280,...more
On July 28, 2022, the Alabama Tax Tribunal held that a corporation is not required to add back interest paid to a related entity as the recipient was subject to tax on that income in Ireland. This was so even though the...more
The European Commission has launched a public consultation on its proposal to introduce a new common EU-wide system for withholding tax on dividend or interest payments. The consultation period will end on 26 June 2022....more
The EU Commission published a public consultation based on its initiative to introduce a common EU-wide system for withholding tax on dividend or interest payments, which includes a system for tax authorities to exchange...more
The thin capitalization tax rules (the “Thin Capital Rules” or the “Rules”) were incorporated into our tax statute in 1992. Then no cases appeared in courts for almost three decades. Recently, however, a new case appeared in...more
In a departure from earlier court decisions, the Massachusetts Supreme Judicial Court (SJC) has imposed additional potential liability on employers for wage-and-hour compliance. In Reuter v. City of Methuen, the SJC explained...more