Martin Hamilton

Jan 22, 2025 | natlawreview.com | Martin Hamilton

On January 20, 2025, the White House issued a memorandum (the “Memorandum”)[1], announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect in the United States” and disavowing “any commitments” previously made by the United States with respect to the Global Tax Deal, absent an act of Congress.

Aug 22, 2024 | proskauertaxtalks.com | Martin Hamilton |Gregory Zeien |Robert A. Friedman

1. Introduction. On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations

Jun 24, 2024 | jdsupra.com | Richard Corn |Martin Hamilton |Amanda H Nussbaum

On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working group” being established in the Large Business and International Division of the IRS.

Dec 5, 2023 | jdsupra.com | Charles Dale |Martin Hamilton |David Hillman

Restructurings defy a one-size fits all approach because every deal is unique and different tools are required to solve different problems. At one end of the restructuring continuum is the so-called “amend and extend,” where the credit agreement is amended to provide incremental liquidity, extend near-term maturities, modify covenants or some combination of the foregoing. This approach is fast and cost-efficient, but limited in its impact.

Dec 4, 2023 | lexology.com | David Hillman |Charles Dale |Steven Peck |Martin Hamilton

Restructurings defy a one-size fits all approach because every deal is unique and different tools are required to solve different problems. At one end of the restructuring continuum is the so-called “amend and extend,” where the credit agreement is amended to provide incremental liquidity, extend near-term maturities, modify covenants or some combination of the foregoing. This approach is fast and cost-efficient, but limited in its impact.