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Articles by Julie Bradlow
OID and CPDI Risks Rise for Debt Issued With Warrants and PIK
Debt instruments issued together with warrants or other equity kickers(opens in new tab) are becoming more common in the private credit market. Both issuers and holders, however, need to be concerned about the proper calculation and reporting of original issue discount (OID). Under the right circumstances, the instrument could even be a contingent payment debt instrument (CPDI), requiring even more detailed calculations.
OID and Contingent Payment Debt Instruments in Private Credit
Debt instruments issued together with warrants or other equity kickers are becoming more common in the private credit market. Both issuers and holders, however, need to be concerned about the proper calculation and reporting of original issue discount (OID). Under the right circumstances, the instrument could even be a contingent payment debt instrument (CPDI), requiring even more detailed calculations.
Qualified Small Business Stock, Recapitalizations and Code Section 305
Many founders of start-up companies organize those businesses as C corporations for a variety of reasons.
Qualified Small Business Stock, Recapitalizations and Code Section 305 | JD Supra
Many founders of start-up companies organize those businesses as C corporations for a variety of reasons.
How Courts and Regulators Are Redefining U.S. Prediction Markets
Prediction markets are platforms where individuals can place bets on the outcome of future events through buying and selling shares in the possible outcomes. These prediction markets sit at the intersection of federal derivatives law and state gambling laws, and the answer to whether they are lawful in the United States turns on preemption, venue, and product design. Federally, prediction markets are regulated by the Commodity Futures Trading Commission (CFTC).
HR Solutions That Become Tax Problems: How to Minimize Risk Original
As organizations increasingly rely on HR-led solutions and third-party vendors to manage benefits, payroll, and compensation to improve efficiency, these solutions often carry hidden tax liabilities that cannot be outsourced and can trigger audits, penalties, and remediation costs. This article highlights the most common pressure points where HR solutions can inadvertently create tax problems, and offers practical strategies for managing risk through improved cross-functional coordination.
How to Minimize Risk
Legal Insights Organizations increasingly rely on HR-led solutions and third-party vendors to manage benefits, payroll, and compensation. While these approaches can drive efficiency, they often carry hidden tax liabilities that cannot be outsourced and can trigger audits, penalties, and remediation costs. In this Legal Insight, I highlight the most common pressure points at the HR–tax intersection and offer practical steps to manage risk through better cross-functional coordination.
HR Solutions That Become Tax Problems: How to Minimize Risk | JD Supra
Organizations increasingly rely on HR-led solutions and third-party vendors to manage benefits, payroll, and compensation. While these approaches can drive efficiency, they often carry hidden tax liabilities that cannot be outsourced and can trigger audits, penalties, and remediation costs. In this DE Insight, I highlight the most common pressure points at the HR–tax intersection and offer practical steps to manage risk through better cross-functional coordination.
The Earnout Equation: Tax Tips for Both Buyers and Sellers | JD Supra
Earnouts are a form of contingent consideration that the buyer of a business pays to the seller in the period following the acquisition, based on the business achieving various financial metrics related to its performance following the change in ownership. They are popular for many reasons. For instance, some buyers prefer an earnout instead of obtaining third party financing.
The Tax Implications of Divorce: Alimony, Child Support, IRAs and More | JD Supra
[c0-author: Sarah Roodenburg] Divorce is a complex and emotionally charged process that also brings substantial financial considerations, with three of the most significant financial aspects of a divorce being alimony (spousal support), child support, and property division under Internal Revenue Code (“Code”)[1] Section 1041. Understanding the tax implications of these decisions is critical, as they can significantly impact the financial stability of both spouses after divorce.
The Tax Implications of Divorce: Alimony, Child Support, IRAs and More
Divorce is a complex and emotionally charged process that also brings substantial financial considerations, with three of the most significant financial aspects of a divorce being alimony (spousal support), child support, and property division under Internal Revenue Code (“Code”)[1] Section 1041. Understanding the tax implications of these decisions is critical, as they can significantly impact the financial stability of both spouses after divorce.
Maximizing Value: The Art of Purchase Price Allocation in Real Estate Deals | JD Supra
When a business is sold, the most important overall aspect of negotiations between a cautious buyer and determined seller may be due to the agreed-upon purchase price for the business. However, when the buyer is purchasing just the assets of the business, the allocation of the purchase price among its various assets is necessary for tax purposes and often receives little to no attention until closer to closing.
IRS Targeting Partnership Basis-Shifting Transaction Schemes | JD Supra
The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In making its announcement, IRS officials stated that closing this loophole could result in over $50 billion in new tax revenue for the U.S. over the next decade.
‘As Such’: Soroban Case Puts Limited Partnerships Under Tax Scrutiny | JD Supra
In Soroban Capital Partners, LP v. Commissioner,[1] the U.S. Tax Court determined that does not automatically apply to all limited partners in a state law limited partnership.
The Brass Tacks: IRS Creates Process for Withdrawing ERC Claims | JD Supra
The Internal Revenue Service (“IRS”) recently granted employers a means to avoid interest and penalties on inappropriately taken Employee Retention Tax Credit (“ERC”) claims.[1] This surely will come as a relief to taxpayers who are (or were) concerned that they may have mistakenly claimed ERCs for tax years 2020-2022.
IRS Response to Israel’s Declaration of War: Relief to Impacted Taxpayers, But Extensions Granted to Its Enforcement Arm | JD Supra
In IRS Notice 2023-71 (the “Notice”), the Internal Revenue Service (“IRS”) granted a postponement until October 7, 2024 for various time-sensitive filing and payment deadlines for taxpayers affected by the terrorist attacks in the State of Israel. The IRS regularly grants extensions of deadlines for all sorts of circumstances. Most commentators, however, have overlooked an important aspect of this Notice, namely the postponement of various other deadlines in favor of the IRS.
Key Questions When Determining Eligibility for State Historic Tax Credits | JD Supra
Real estate developers have long had ample reasons to take on projects involving historic buildings, courtesy of Section 47 of the Internal Revenue Code of 1986. As amended, Section 47 (the “Code”) provides for a rehabilitation tax credit, also commonly known as the historic tax credit (“HTC”) equal to 20% of qualified rehabilitation expenditures (“QREs”) with respect to a qualified rehabilitated building (“QRB”), taken over the five-year period beginning in the year the QRB is placed in service.
How IRS Is Cracking Down on Employee Retention Tax Credit Fraud | JD Supra
The Internal Revenue Service (“IRS”) has recently devoted great attention to detecting, investigating, and prosecuting fraud, particularly as it relates to the Employee Retention Tax Credit (“ERC”) post-COVID. On a webinar broadcast on July 25, 2023, hosted by the IRS’s Office of Fraud Enforcement and National Fraud Counsel, the presenters noted that ERC claims top the IRS’s “Dirty Dozen” list of tax scams at the moment.
Do It Better Than ‘Succession’: How to Optimize Transition for Your Waystar Royco | JD Supra
Over the past three seasons, fans of the hit HBO series Succession [1] have had an entrée into the fabulous lifestyles enjoyed by members of the Roy family and a front-row seat from which to observe the myriad succession struggles the family faces. While not every business experiences the same palace intrigue as the Waystar Royco media conglomerate, there are still many issues to consider when addressing your own company’s future and legacy.
Trust me. You Need a Trust. | JD Supra
So, you finally sat down to start your estate plan but have heard so many conflicting points about wills and trusts that you don’t know where to start. If you are choosing between a trust and a will, you’re not alone. One of the biggest reasons people choose a trust is because it eliminates the need for litigation and the court process. If you leave just a will behind, you must appoint someone as the executor to fulfill your wishes.
Here Comes the Sun: The Inflation Reduction Act Provides a Multitude of New Tax Incentive Opportunities for the Solar Industry | JD Supra
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (“IRA” or the “Act”) into law. The IRA, which contains several energy-related tax credits and extends and modifies some existing credits in the Internal Revenue Code of 1986 (the “Code”), is aimed at boosting clean energy initiatives.
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