The best way to learn about the tax considerations for buyers and sellers in M&A transactions is to study the different M&A deal types. This practice note focuses on the typical tax consequences...
While landlords initiate many evictions for rent payment defaults, they also evict tenants for other lease breaches and violations of federal, state, or local laws. Both landlords and tenants should familiarize...
Representations and warranties insurance (RWI) continues to evolve to meet the challenges of today’s M&A market. Keep your skills and knowledge sharp with RWI resources from Practical Guidance...
Are you interested in recent key legal developments in transgender law in the workplace? Watch our new Transgender Employee Compliance in the Workplace: Key Employer Steps Video , by Kimberley E. Lunetta...
The IRS Office of Chief Counsel recently considered consolidated group membership in determining the arm’s length rate of interest chargeable for intragroup loans and making a section 482 adjustment. Under the section 482 regulations, the arm’s length rate of interest on an intragroup loan to a controlled borrower is generally the rate at which that borrower could realistically obtain alternative financing from an unrelated party. Thus, if an unrelated lender would consider group membership in establishing financing terms available to the borrower, and such third-party financing is realistically available, then the IRS may adjust the interest rate in a controlled lending transaction to reflect group membership.
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