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    Trade alert - Australia
    2014-12-01

    Australia is a member of both the Basel Committee and the G20 and in November, Brisbane was host to the G20 Leaders' Summit.

    The agenda focussed on increasing global growth, jobs and economic stability.  Despite the positive G20 intentions, David Cameron was quoted as saying "red warning lights are once again flashing on the dashboard of the global economy".

    Filed under:
    Australia, Banking, Corporate Finance/M&A, Insolvency & Restructuring, Litigation, Tax, Cadwalader Wickersham & Taft LLP, Stamp duty
    Authors:
    Louisa Watt
    Location:
    Australia
    Firm:
    Cadwalader Wickersham & Taft LLP
    Trade alert - Turkey
    2014-10-31

    Turkish corporates have increasingly utilised international debt markets in the last decade, particularly in the infrastructure and energy sectors. These corporates are now under pressure due to recent political instability and depreciation of the Turkish lira. Restructuring candidates in 2014 have included Yuksel, the construction company which was last in discussions with bondholders and local lenders mid-year. Below we take a look at key legal issues for loan traders in Turkey.

    Filed under:
    Turkey, Banking, Corporate Finance/M&A, Insolvency & Restructuring, Litigation, Tax, Cadwalader Wickersham & Taft LLP
    Authors:
    Louisa Watt
    Location:
    Turkey
    Firm:
    Cadwalader Wickersham & Taft LLP
    IRS issues new regulations defining “publicly traded property” for purposes of determining the issue price of debt instruments that are significantly modified in a restructuring or issued for property
    2012-09-26

    I. Summary

    Filed under:
    USA, Banking, Capital Markets, Insolvency & Restructuring, Tax, Cadwalader Wickersham & Taft LLP, Public company, Debt, Securities Exchange Act 1934 (USA)
    Location:
    USA
    Firm:
    Cadwalader Wickersham & Taft LLP
    Sale free and clear: permitted “matters of record” may be broader than you expect
    2014-07-15

    In re Joan Fabrics Corp., 508 B.R. 881 (Bankr. D. Del. 2014) –

    The buyer of assets in a bankruptcy sale sought to enforce its asset purchase agreement against a county that was seeking to collect personal property taxes arising prior to the sale by exercising a statutory lien on the property acquired by the buyer.

    Filed under:
    USA, Delaware, Insolvency & Restructuring, Litigation, Real Estate, Tax, Troutman Pepper, Property tax, Personal property
    Location:
    USA
    Firm:
    Troutman Pepper
    Ad valorem property taxes: deadline for challenging in a bankruptcy
    2012-12-11

    Pinellas County Property Appraiser v. Read (In re Read), 692 F3d 1185 (11th Cir. 2012) –

    Under Section 505(a)(1) of the Bankruptcy Code, generally a bankruptcy court may determine the amount or legality of any tax. However, under Section 505(a)(2)(C) of the Bankruptcy Code ad valorem real or personal property taxes cannot be contested if the applicable time period under non-bankruptcy law has expired.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Tax, Troutman Pepper, Bankruptcy, Debtor, Property tax, Interest, Personal property, Title 11 of the US Code
    Location:
    USA
    Firm:
    Troutman Pepper
    Valuing collateral: do low-income housing tax credits count?
    2012-11-27

    In re Creekside Senior Apartments, LP, 477 B.R. 40 (6th Cir. B.A.P. 2012) –

    In valuing a bank claim secured by a low-income housing project for purposes of a plan of reorganization, should the remaining federal low‑income housing tax credits allocated to the project be taken into consideration?  In Creekside the bankruptcy court said yes, and the bankruptcy appellate panel agreed.

    Filed under:
    USA, Banking, Insolvency & Restructuring, Litigation, Real Estate, Tax, Troutman Pepper, Debtor, Collateral (finance), Tax credit, Limited partnership
    Location:
    USA
    Firm:
    Troutman Pepper
    Delinquent property tax collection: foreclosure may be vulnerable
    2012-09-25

    Williams v. City of Milwaukee City Clerk (In re Williams), 473 B.R. 307 (Bankr. E.D. Wis. 2012) –

    Filed under:
    USA, Banking, Insolvency & Restructuring, Litigation, Tax, Troutman Pepper, Property tax, Mortgage loan, Foreclosure, Fair market value, Tax lien
    Location:
    USA
    Firm:
    Troutman Pepper
    Sixth Circuit holds that supplemental unemployment compensation benefits are not ‘wages’ subject to FICA taxation
    2012-09-10

    In an important recent decision, United States v. Quality Stores, Inc., et al.,1 in which Pepper represented the prevailing party, the U.S. Court of Appeals for the Sixth Circuit held that supplemental unemployment compensation benefits (SUB payments) paid by a bankrupt company to its former employees were not wages subject to taxation under the Federal Insurance Contributions Act (FICA).

    Filed under:
    USA, Employee Benefits & Pensions, Insolvency & Restructuring, Litigation, Tax, Troutman Pepper, Wage, Unemployment benefits, Federal Insurance Contributions Act tax, Severance package, Internal Revenue Service (USA), Sixth Circuit
    Authors:
    Michael H. Reed , Lisa B. Petkun
    Location:
    USA
    Firm:
    Troutman Pepper
    Bankruptcy PLR with NOL preservation result
    2012-08-14

    Section 382 limits a loss corporation’s ability to use its Net Operating Losses (NOLs) carryforwards following an "ownership change."1 An ownership change is triggered if one or more "5-percent shareholders" of the loss corporation increase their ownership in the aggregate by more than 50 percentage points during a testing period. Following an ownership change, the "Section 382 limitation" generally reduces the ability to use NOLs to offset taxable income in any post-change year.2

    Filed under:
    USA, Insolvency & Restructuring, Tax, Troutman Pepper, Bankruptcy, Interest, Debt, Internal Revenue Service (USA)
    Location:
    USA
    Firm:
    Troutman Pepper
    Conversion of insolvent corporation into a tax partnership: IRS reaches favorable conclusions, but questions remain
    2011-11-21

    Introduction

    Filed under:
    USA, Insolvency & Restructuring, Tax, Troutman Pepper, Shareholder, Debt, Liability (financial accounting), Liquidation, Internal Revenue Service (USA)
    Location:
    USA
    Firm:
    Troutman Pepper

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