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Raising capital for real estate investments can be a challenge — especially when seeking funding from outside the United States. However, with the right strategy, real estate sponsors — and the developers they often partner with — can access a broader pool of global investors and significantly improve tax efficiency.
This unique approach combines a C-corporation structure with portfolio interest exempt notes — debt instruments that allow U.S. borrowers to pay interest to foreign investors without triggering U.S. withholding tax. To qualify, the notes must be in registered form and cannot be held by a 10% or greater shareholder of the issuing entity, in addition to certain other conditions being met.
Why is it that those who are best skilled at advocating for others are ill-equipped at advocating for their own skills and what to do about it?
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
Active reading comprises many daily tasks lawyers engage in, including highlighting, annotating, note taking, comparing and searching texts. It demands more than flipping or turning pages.
With trillions of dollars to keep watch over, the last thing we need is the distraction of costly litigation brought on by patent assertion entities (PAEs or "patent trolls"), companies that don't make any products but instead seek royalties by asserting their patents against those who do make products.