The rates of default on corporate borrowing are expected to rise globally, presenting more opportunities for distressed debt investors. Key tax considerations for investment funds investing in distressed debt assets include: interest limitation rules on asset holding entities within investment fund structures; potential implications of debt release and similar transactions; risks associated with loan origination activities; and considerations arising in relation to enforcement of security.
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The rates of default on corporate borrowing are expected to rise globally, presenting more opportunities for distressed debt investors. Key tax considerations for investment funds investing in distressed debt assets include: interest limitation rules on asset holding entities within investment fund structures; potential implications of debt release and similar transactions; risks associated with loan origination activities; and considerations arising in relation to enforcement of security.
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