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USA - March 31 2010
As discussed in our prior issue of MoFo Tax Talk (see MoFo Tax Talk, Volume 2, Issue 1), debt issues are often "reopened," meaning that an issuer issues an additional tranche of notes ("additional notes") at some point after the original issuance ("original notes").
USA - March 31 2010
As discussed in our prior client alert "FATCA Provisions Enacted Into Law: New Withholding Tax, Ban on Bearer Bonds, and Withholding on Dividend Equivalents," on March 18, 2010, President Obama signed into law the HIRE Act.
USA - March 31 2010
In resolving what has long been an uncertain issue, the Tax Court held, in an opinion dated February 17, 2010, that a U.S. corporate subsidiary of a Mexican parent company was not required to withhold U.S. federal income taxes from the guaranty fees the subsidiary paid to its parent in connection with guaranteeing its debt.
USA - March 31 2010
As we previously discussed in our prior issue of MoFo Tax Talk and elsewhere (see e.g., MoFo Tax Talk, Volume 2, Issue 4, “Contingent capital instruments,” and “Is it a bird? A plane? Exploring contingent capital”) contingent capital instruments are a novel hybrid security intended to provide a buffer for financial institution issuers during times of stress, when financial institutions may find it difficult to access the market in order to bolster their regulatory capital levels.
USA - March 31 2010
As discussed in our client alert, "Reconciliation Bill Codifies 'Economic Substance' Doctrine, Expands Medicare Taxes on High-Income Earners and Imposes Reporting Requirements on Certain Payments to Corporations," on March 30, 2010, President Barrack Obama signed into law the Health Care and Education Reconciliation Act of 2010, which supplements the Patient Protection and Affordable Care Act, which was signed into law on March 23, 2010.
