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IRS issues economic substance “guidance”
- Morrison & Foerster LLP
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- USA
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- October 13 2010
As we reported two issues ago in this publication, the "economic substance doctrine" has been codified
Medicare tax on the sale of a principal residence?
- Morrison & Foerster LLP
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- USA
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- October 13 2010
As discussed in our prior client alert, “Reconciliation Bill Codifies ‘Economic Substance’ Doctrine, Expands Medicare Taxes on High Income Earners and Imposes Reporting Requirements on Certain Payments to Corporations,” to pay for health care reform, among other revenue raisers, the Health Care Act introduced a 3.8 Medicare contribution tax (the “Medicare tax”) on unearned income (i.e., income other than from wages) of certain high income earners
Small Business Jobs Act affects source rules for guarantee fees
- Morrison & Foerster LLP
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- USA
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- October 13 2010
As discussed in our prior client alert "Small Business Jobs Act of 2010Key Revenue-Raising Provisions," the Small Business Jobs Act of 2010 (signed into law on September 27, 2010) includes $12 billion in tax cuts aimed at small businesses and several revenue raising provisions
Prepaid forward plus stock loan equals sale according to U.S. Tax Court
- Morrison & Foerster LLP
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- USA
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- October 13 2010
On July 22, 2010, the U.S. Tax Court ruled against the taxpayer in Anschutz v. Comm’r, the widely followed U.S. prepaid forward plus stock loan case
ISDA 2010 HIRE Act protocol
- Morrison & Foerster LLP
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- Global, USA
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- October 13 2010
As discussed in more detail in a prior issue of MoFo Tax Talk, the HIRE Act treats as a U.S.-source dividend any “dividend equivalent” for purposes of U.S. withholding tax provisions
Did you catch that, again?
- Morrison & Foerster LLP
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- USA
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- October 13 2010
In our first quarter 2010 issue, we included a piece entitled "Did You Catch That?", which addressed select provisions in new legislation that tinkered with (by increasing) the amount of estimated taxes that certain large corporations must pay over the course of a future year, effectively providing the government with a short-term loan
The classroom fixed-to-floaters
- Morrison & Foerster LLP
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- USA
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- October 13 2010
Fixed-to-floating rate notes appear to becoming more popular for fixed-income investors lately
Proposed regulations clarify ambiguity
- Morrison & Foerster LLP
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- USA
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- July 16 2010
As discussed in prior editions of MoFo Tax Talk,1 an exchange of property for other property differing materially either in kind or in extent is generally treated as a taxable exchange for U.S. federal income tax purposes
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- Author - Stephen L. Feldman
- Author - Anna T. Pinedo
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