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
Remmelt Reigersman
Reopenings: Issuing Additional Debt Securities of an Outstanding Series
By Remmelt Reigersman & John Berkery on
This Lexis Practice Advisor practice note discusses reopenings of debt securities issuances. Companies frequently raise capital by issuing additional debt securities of the same series as debt securities outstanding under an existing indenture, often referred to as “reopening the indenture” or “reopening the series.”
Read the full article here.
Debt Restructuring During the COVID-19 Pandemic – Key Tax Considerations
By Remmelt Reigersman & Brennan W. Young on
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…
How to Structure a Tax-Efficient IPO: Benefits of the Up-C Structure
By Gonzalo Go, Remmelt Reigersman & Anna T. Pinedo on
Posted in IPOs, Up-C Structure
A partnership (or LLC) can go public in a highly tax-efficient manner by using an “Up-C” structure. An Up-C structure is composed of two entities: (1) a parent company, a C corporation (“PubCo”) which will be organized as a holding company, and (2) PubCo’s subsidiary, which is the partnership or LLC. The Up-C structure makes…