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A Tax Planning “Hat Trick” for Funds Acquiring Portfolio Company Debt

As a result of the COVID-19 pandemic, many companies are having difficulty meeting payment obligations on their outstanding debt. However, thanks to a combination of the U.S.-Irish income tax treaty and Section 108 of the Internal Revenue Code of 1986, as amended (the “Code”), private equity funds (and other funds) may be able to find…

Client Alerts | July 9, 2020 | Business Advice and Planning | Private Equity Funds

More Global High-Wealth Audits Expected Soon

The Commissioner of the IRS Large Business and International Division recently announced that the Global High Wealth Industry Group of the IRS will initiate several hundred audits of high-wealth individuals. The audits are expected to commence beginning July 15 when the suspension of certain examination and collection functions of the IRS is lifted. A representative…

Client Alerts | June 22, 2020 | Business Advice and Planning | High Net Worth Individual Planning

Unexpected Tax Consequences of Commercial Lease Modifications

In a prior Kleinberg Kaplan client alert, we noted that COVID-19 related economic disruptions have caused both landlords and tenants to consider restructuring their commercial lease arrangements. Tenants that enter into discussions with landlords seeking rent relief may be successful. However, landlords and tenants should be aware that they could run into unexpected tax consequences in…

Client Alerts | April 30, 2020 | Business Advice and Planning | Leasing

Summary of Key Tax Provisions for Individuals and Businesses under the CARES Act

The Coronavirus Aid, Relief, and Economic Security Act ( the “CARES Act”) was signed into law on Friday, March 27, 2020.  The CARES Act contains a number of tax provisions which modify the Internal Revenue Code of 1986, as amended (the “Code”).  The provisions are designed to provide relief and assistance to both individuals and…

Client Alerts | March 30, 2020 | Business Advice and Planning | High Net Worth Individual Planning