Brennan W. Young

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Limited US Tax Guidance for Adding ARRC and ISDA Fallbacks

By Steven D. Garden, Russell E. Nance, Remmelt Reigersman, Brennan W. Young & Thomas A. Humphreys on October 16, 2020

On Friday, October 9, 2020, the Internal Revenue Service released Revenue Procedure 2020-44 (the “Revenue Procedure”), providing retroactive but limited relief for amending specific types of legacy contracts to add fallback mechanics for the London Interbank Offer Rate or other Interbank Offer Rates. The fallback granted relief by the Revenue Procedure must rather strictly follow…

Debt Restructuring During the COVID-19 Pandemic – Key Tax Considerations

By Remmelt Reigersman & Brennan W. Young on April 14, 2020

Posted in COVID-19, Debt Offerings, Liability Management, Tax

Businesses are under unprecedented stress due to the global COVID-19 pandemic. Many of these businesses need some form of relief on their debt obligations in order to avoid triggering defaults, foreclosures and collection activity during this extraordinary period of economic inactivity. There is no one way to structure a workout. The workout structure can be…