The Tax Cuts and Jobs Act significantly changed many aspects of business taxation, especially for distressed companies. The way net operating losses work has fundamentally changed. The ability to deduct interest expense is now significantly limited and, as a result, distressed companies may have very different tax profiles than they previously have had. Changes to several rules impact the decision on whether to structure a reorganization as a tax-free transaction or a “Bruno’s” taxable transaction. The international tax regime has been fundamentally altered, both with respect to normal operations and with respect to long-standing issues regarding the appropriate scope of pledges and guarantees that can be provided in connection with DIP financing and cash collateral packages. All of these rules remain subject to an active and very much ongoing regulatory process that places a significant degree of uncertainty around tax outcomes. The panel will highlight and contextualize these key issues so that restructuring specialists can be aware of their potential impact.
Tuesday, February 19
12 Noon - 1:15 pm ET
CLE is available in qualifying states.*
*1 hour of general CLE credit is available in the following pre-approved 60-minute-hour and 50-minute-hour states: AK, AL, AR, CA, DE, GA, IL, MO, NJ, PA, SC, TN, TX, VT, WI, and WV. These states follow an approved jurisdiction policy: AZ, CO, CT, NH, NY. ABI will submit attendance to DE, IL, NV, PA, TN, and TX. For those jurisdictions not listed,ABI will not seek direct accreditation attorneys will need to self-submit. Some states allow may not allow self-submission. ABI will issue certificates for attorneys to self-submit for approval. ABI charges an administrative fee of $5 for Members and $25 for non-members upon requesting CLE credit for this program. Further details will be provided the day of the event.