Tag Archives: foreign

Avoiding the Unintended Tax Consequences of Foreign Subsidiary Pledges and Guarantees: A Look at Deemed Dividends in U.S. Loan Transactions

This post was also written with assistance from Abbey Mansfield . Overseas Shipping Group (“Overseas”) recently sued its former attorneys, a prominent New York-based law firm, for legal malpractice in drafting credit agreements that resulted in the company incurring an estimated $463 million in tax liability. The suit alleges that the tax liability arises from the fact … Continue Reading

Inbound Loans: An Opportunity for International Banks in the U.S.

This post was also written with assistance from Jordan Hook. Foreign and international banks are increasingly presented with opportunities to lend to the U.S. subsidiaries of their foreign clients through their U.S. branches.  These opportunities exist partially due to the fact that regulations abroad have constrained lending, and foreign parent companies are looking to the … Continue Reading
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