News & Analysis as of

Lenders Income Taxes

Cadwalader, Wickersham & Taft LLP

An option to dispose of property does not necessarily give rise to a taxable disposal

In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more

Mayer Brown

Exploring the Unexpected and Often Unwelcome Federal Income Tax Consequences of Debt Modifications

Mayer Brown on

As a number of debt instruments issued several years ago in a relatively low interest rate environment now have their maturity date approaching in a much higher interest rate environment, borrowers are increasingly seeking to...more

International Lawyers Network

Buying and Selling Real Estate in England and Wales (Update)

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER BRITISH LAW - 1. Introduction - Historically, there has been significant investment by overseas individuals and corporations in real estate in England and Wales and in...more

International Lawyers Network

Buying and Selling Real Estate in England and Wales (Updated)

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER BRITISH LAW - 1. Introduction - Historically, there has been significant investment by overseas individuals and corporations in real estate in England and Wales and in...more

Rivkin Radler LLP

Selling Your Business? Take the Money But Defer the Tax?

Rivkin Radler LLP on

Sale of the Business- Imagine Client has just received an attractive, all cash offer for the sale of their business; there is no financing contingency. The buyer has proposed a cash-free and debt-free deal....more

International Lawyers Network

Buying and Selling Real Estate in England and Wales (Updated)

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER BRITISH LAW - 1. Introduction - Historically, there has been significant investment by overseas individuals and corporations in real estate in England and Wales and in...more

McGlinchey Stafford

1099-C Discharge Without Debt Cancellation Not Consumer Protection Law Violation

McGlinchey Stafford on

Once again, a borrower who argued his debt was cancelled when he received an IRS Form 1099-C was told by the court that it was merely discharged. The court says “discharge” is not “actual discharge.” While acknowledging that...more

International Lawyers Network

Buying and Selling Real Estate in England and Wales

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER BRITISH LAW - 1. Introduction - Historically, there has been significant investment by overseas individuals and corporations in real estate in England and Wales and in...more

McGlinchey Stafford

When Is Form 1099-C Required of Lenders? [More with McGlinchey, Ep. 16]

McGlinchey Stafford on

When debt is forgiven, as much of the funding lent through the CARES Act’s PPP may be, a lender may be required to file IRS Form 1099-C with the IRS and to furnish a copy to the borrower. As a lender, do I need to file the...more

Gerald Nowotny - Law Office of Gerald R....

THE WONDER YEARS WEBINAR

Loan Regime Method of Split Dollar Life Insurance - This webinar covers: What is Split Dollar? Loan Method versus Economic Benefit. Leverage Split Dollar Rollout. Planning examples using Split Dollar....more

Gerald Nowotny - Law Office of Gerald R....

HEAVEN CAN WAIT

Nowotny On Death and Taxes podcast episode #24, discusses using the Loan Method of Split Dollar in the After-Life!...more

Pillsbury Winthrop Shaw Pittman LLP

Distressed Real Estate During the COVID-19 Pandemic: Deeds in Lieu of Foreclosure Involving Commercial Real Estate

In a deed in lieu of foreclosure, a defaulting borrower agrees to convey the mortgaged property to the mortgage lender. But handing over the keys can raise a number of potential pitfalls. Below, we discuss some of these...more

Womble Bond Dickinson

10 Key Considerations for Commercial Real Estate Loan Restructurings: A Primer

Womble Bond Dickinson on

The tragic and widespread effects of COVID-19 continue to unfold on a daily basis. The pandemic’s impact from both a public health and economic perspective has been literally unfathomable. For commercial real estate owners,...more

Troutman Pepper

How to Navigate the After Effects of the U.S. Stimulus Packages

Troutman Pepper on

Your company received stimulus funding, what do you need to know now? Join us for an update on the Paycheck Protection Program and other funding packages as well as a discussion of what you need to know to stay compliant and...more

Locke Lord LLP

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

Locke Lord LLP on

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

Farrell Fritz, P.C.

Business Resources and Recovery (UPDATED)

Farrell Fritz, P.C. on

Businesses grappling with the economic impact of the ongoing COVID-19 crisis have the opportunity to apply for financial assistance through a variety of Federal, State and Local programs. ...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Issues FAQs and Form 7200 for Advance Payment of COVID-19 Employer Tax Credits

The IRS has issued FAQs regarding the tax credits for the sick and family leave and employee retention tax credits which provide guidance on eligibility and instructions for claiming the credits. The guidance sets forth the...more

Pillsbury Winthrop Shaw Pittman LLP

CARES Act Planning Opportunities for Retirement Accounts and Charitable Giving

Taking advantage of retirement account planning and charitable giving opportunities created under the new stimulus package. Required Minimum Distributions are waived for 2020, allowing further income tax deferral until at...more

Foley & Lardner LLP

IRS Issues Guidance on Employee Retention Credits Under CARES Act

Foley & Lardner LLP on

On March 31, 2020, the IRS issued guidance on the Employee Retention Credits under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). The Employee Retention Credits are fully refundable tax credits...more

Farrell Fritz, P.C.

Guarantees: Tax Considerations And Surprises

Farrell Fritz, P.C. on

Don’t Take It Lightly- Regardless of who or what they are, taxpayers have to be careful of saying things like, “I guarantee it” or “it’s guaranteed.” First of all, they’re not Joe Namath guaranteeing a Jets victory over...more

International Lawyers Network

Buying and Selling Real Estate in England, Wales, and North Ireland

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER BRITISH LAW. Introduction - Historically, there has been significant investment by overseas individuals and corporations in real estate in England and Wales and in particular in...more

Proskauer Rose LLP

UK Tax Round Up - June 2018

Proskauer Rose LLP on

Streaming of losses on trade succession (Leekes v. HMRC) - This case involved a taxpayer who purchased a business (the "predecessor business") and combined it with their existing business (creating the "enlarged...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

Foster Garvey PC on

“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

Miles & Stockbridge P.C.

Taxpayer Entitled to Capital Loss from Property Foreclosure for Year of Sale, Not When Proceeds Received

Evans v. Commissioner, T.C. Memo. 2016-7, was recently decided. The taxpayer in this case was an individual who worked full-time at a real estate development firm. The taxpayer also purchased residential real estate...more

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