Tax

Subscribe to Tax

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…

Portfolio 5507 discusses the securities laws applicable to foreign private issuers that access the U.S. capital markets and the integrated disclosure system.

This most recent edition includes updates for foreign private issuers, and the financial intermediaries that work with foreign private issuers, in connection with public offerings and exempt offerings.

The portfolio has been updated…

Lexis Practice Advisor

This practice note covers recent market trends affecting business development companies (BDCs), particularly focusing on various types of securities offerings undertaken by public and private BDCs. BDCs are closed-end investment management companies that are specially regulated by the Investment Company Act of 1940, as amended (the 1940 Act). BDCs provide capital to,…

Wednesday, October 7, 2020
12:00pm to 1:30pm EDT
Register here.

Mayer Brown’s Benefits & Compensation University has expanded from our annual Executive Compensation University to include health, welfare and qualified plan issues. During this series of webinars, we will explore benefit and compensation issues in depth and hear from leading Mayer Brown lawyers about…

Just as with debt instruments between unrelated parties, the current economic downturn may cause related parties to want to modify the terms of debt instruments existing between them. And as with debt instruments between unrelated parties, modification of debt instruments between related parties may have a number of tax consequences. What constitutes a “modification” and…

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.

Webinar
April 28, 2020
1:00 pm – 2:00 pm ET
Register here.

This presentation will address the current US tax rules and any new developments regarding structured products, including:

  • The tax characterization of structured notes;
  • The dividend equivalent provisions and current state of play;
  • The IRS basket option notices; and
  • PFIC and FIRPTA considerations.

May 6, 2020
1:00 – 2:00 PM ET
Register here.

During this webinar, the presenters will discuss the tax implications to issuers and investors resulting from various liability management transactions, including:

  • Debt repurchases;
  • Debt modifications or exchanges;
  • Recapitalizations;
  • Bankruptcy restructurings; and
  • Payment of consent fees.

CLE credit is pending.

 

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…