Tax Considerations for Commercial Loan Documents
1 hour 30 minutes
Understand available options and evaluate the tax consequences related to different aspects of commercial loan documents.
In the Post-TCJA and CARES Act era, commercial loans have faced sudden and uncertain pressures. Loan document drafting, restructuring, and forgiveness can provide opportunities for borrowers and lenders. However, they are often accompanied by significant tax consequences that can have long-term financial effects on borrower, lenders, and investors.
This material will help you understand available options and evaluate the tax consequences related to different aspects of commercial loan documents. This will help you evaluate the tax consequences loan modifications for borrowers, lenders and investors.
• You will be able to describe tax implications of the CARES Act and the TCJA on commercial loan documents.
• You will be able to discuss limitation on the deductibility of business interest expense under new IRC Section 163(j).
• You will be able to explain why pledges and guarantees by foreign subsidiaries are an important consideration.
• You will be able to identify several ways in which a loan may be restructured to take advantage of the new rules after tax reform and the CARES Act.