Scott Singer Informs On the Effect of Loans to Financially Troubled Subsidiary in a Debt-Equity Analysis

By | Tax Controversy 360 | August 26, 2016

One often overlooked debt-equity issue is presented by continuing transfers to a subsidiary that is reasonably creditworthy at the inception but subsequently encounters difficulties, in spite of which (or maybe because of which) and continues to receive advances from the common parent or one of its finance subsidiaries.

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IRS Relaxes Restrictions On Management Contracts for Bond-Financed Facilities

By | Public Finance Matters | August 24, 2016

The IRS on August 22, 2016 released long-anticipated Revenue Procedure 2016-44 (Rev. Proc. 2016-44), which substantially increases flexibility in, and provides a less formulaic approach to, the ability of a tax-exempt bond issuer or 501(c)(3) conduit borrower to contract with private parties without jeopardizing the tax-exemption of bonds that financed the facilities at which the applicable services are provided.

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