New York, NY
On December 13, 2016, Cleary Gottlieb partner Erika W. Nijenhuis was a panelist on the International Tax Institute’s panel on An In-Depth Look at the “Loan Origination” Issue.
The panelists explored the possibility of developing a new paradigm for analyzing loan origination transactions. The first paradigm considered was based on factors taken into account under current law. The second was a more radical attempt to distinguish service incomes from return on capital.