Larry Crouch

Aug 12, 2024 | lexology.com | Larry Crouch |Ryan Bray |Jay Singer |Matthew Brown |José Germano Rego |José Márcio Rêgo

On August 6, 2024, the U.S. Treasury Department (“Treasury”) issued proposed regulations under section 1503[1] (the “Proposed Regulations”) that address the interaction between the dual consolidated loss (“DCL”) rules and the Global Anti-Base Erosion Rules (Pillar Two) (“Pillar Two Rules”),[2] among other DCL issues.[3] If finalized, the Proposed Regulations would increase the relevance of the DCL rules for many U.S. consolidated groups with foreign affiliates either above or below such U.S....

Jan 18, 2024 | mondaq.com | Larry Crouch

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Jul 27, 2023 | mondaq.com | Larry Crouch

Shearman & Sterling advised Toyota Motor Corporation in connection with its U.S. dollar sustainability bond offering, consisting of $500 million 5.275% senior notes due 2026, $500 million 5.118% senior notes due 2028 and $500 million 5.123% senior notes due 2033. The net proceeds of the notes will be allocated to new or existing "Eligible Projects" defined under Toyota's Woven Planet Bond Framework (Sustainability Bond Framework).