Inflation Reduction Act
Supermajors, dividends and the energy transition
I am sitting in my garden at home on a sunny afternoon with a glass of white wine – and yes I had booked this day off as leave. I check my phone and see that all hell is breaking...
SEC Leaders Ask Municipal Issuers for Voluntary COVID-19 Disclosure
On May 4, Securities and Exchange Commission Chairman Jay Clayton and Rebecca Olsen, Director of the SEC’s Office of Municipal Securities, issued a statement entitled “The Importance of Disclosure for our Municipal Markets” 1 stating that “in light of the...
IRS Relief for Governmental Issuers Seeking to Temporarily Buy Back VRDOs and Commercial Paper
Responding to volatility in the market and liquidity constraints caused by the COVID-19 pandemic, in Notice 2020-25 (the “Notice”), the IRS provides temporary relief for governmental issuers seeking to purchase their own tax-exempt variable rate demand obligations that are “qualified...
Bracewell Legal Bites: Contingent Price Adjustments and Volatile Oil Prices
What 5 key points do buyers and sellers need to negotiate to get oil and gas deals done in today’s challenging market? Alastair Young , a partner in Bracewell’s London office, shares his perspective. View video.
New Guidance: SBA Clarifies That Foreign Employees Must Be Counted for PPP
The Small Business Administration has clarified through newly-issued guidance that employees of foreign affiliates must be counted when determining the size of a business for eligibility under the Paycheck Protection Program. This new guidance, which is part of a steady...
IRS Allows Telephonic TEFRA Hearings in Light of COVID-19
As a result of the prohibitions on public gatherings resulting from the COVID-19 pandemic, issuers of tax-exempt private activity bonds have been facing difficulty complying with the federal tax laws requiring that a public hearing be held to allow interested...
IRS Relaxes UBTI "Siloing" Rules for Most Exempt Organizations
On April 23, 2020, the IRS and the Treasury Department released Proposed Regulations that provide guidance for how tax-exempt organizations (“EOs”) conducting multiple unrelated trades or businesses can calculate their unrelated business taxable income (“UBTI”) in light of the enactment...
CARES Act Update: IRS and Treasury Department Release Net Operating Loss Guidance
On April 9, 2020, the IRS and Treasury Department released Revenue Procedure 2020-24 (the Revenue Procedure) and Notice 2020-26 (the Notice). The Revenue Procedure provides technical guidance for corporations with respect to the net operating loss (NOL) provisions of the...
Labor & Employment Webinar: Have Questions? Get Answers
The volume of evolving information arising out of the coronavirus pandemic is astounding. How do employers sort through it all to know what is important for your company and role within the organization? Bracewell’s webinar aims to help. Our Labor...
Mnuchin Warns of Criminal Liability for PPP; Promises to Audit Large Loans
On April 28, Treasury Secretary Steven Mnuchin announced the SBA would be conducting audits of all businesses that received greater than $2 million in PPP loans, reiterating his warning from last week that businesses borrowing under the Paycheck Protection Program...
CARES Act Update: IRS and Treasury Department Issue Guidance Under Code Section 163(j)
On April 10, 2020, the IRS and Treasury Department released Revenue Procedure 2020-22 (the Revenue Procedure), providing guidance with respect to the application of the provisions of the Coronavirus Aid, Relief, and Economic Security (CARES) Act relating to the limitation...
New SBA Guidance: Private Equity Eligibility, Debtors in Bankruptcy, and a Safe Harbor
Shortly after the passage of a bill injecting an additional $310 billion into the Small Business Administration’s Paycheck Protection Program, the SBA has issued another supplemental Interim Final Rule (IFR) providing new guidance on several issues, including eligibility for hedge...
Willfulness Not a Prerequisite for Trademark Infringer’s Profits
U.S. Supreme Court settles circuit split over whether plaintiffs must prove willful infringement in order to recover a defendant’s profits The Supreme Court’s decision Thursday in Romag Fasteners, Inc. v. Fossil, Inc. significantly expanded the monetary relief available for trademark...
Bracewell Legal Bites: 5 Things to Consider About Force Majeure Relief
During the coronavirus lockdown, many companies are turning to their contracts to consider whether relief might be available under force majeure provisions. Watch this Bracewell Legal Brief , where Darren Spalding , a partner in our London office, details 5...
Bracewell Legal Bites: 5 Things to Consider About Force Majeure Relief
During the coronavirus lockdown, many companies are turning to their contracts to consider whether relief might be available under force majeure provisions. Watch this Bracewell Legal Brief, where Darren Spalding, a partner in our London office, details 5 key issues...