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Results: 1-10 of 74

IRS issues economic substance “guidance”

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 13 2010

As we reported two issues ago in this publication, the "economic substance doctrine" has been codified

Press corner

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 13 2010

Taxes on sliced bagels?

Medicare tax on the sale of a principal residence?

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • 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

ISDA 2010 HIRE Act protocol

  • Morrison & Foerster LLP
  • -
  • Global, USA
  • -
  • 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
  • -
  • USA
  • -
  • 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

Small Business Jobs Act affects source rules for guarantee fees

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • 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
  • -
  • USA
  • -
  • 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

Calloway v. Comm’r

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 16 2010

Calloway v. Comm’r, decided on July 8, 2010, in the Tax Court, held (i) that a purported non-recourse loan equal to 90 of the value of stock held by a taxpayer was, in substance, a sale for U.S. federal income tax purposes, and (ii) that the transaction was not a securities lending arrangement under Section 1058 of the Code

From Extender’s Act to American Act to American jobs

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 16 2010

Representative Charles Rangel (D - New York) introduced the Tax Extenders Act of 2009 (the "Bill") on December 7, 2009

The classroom

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 16 2010

A regulated investment company ("RIC") is a tax-favored vehicle that receives the benefit of avoiding an entity level tax through a dividends paid deduction if several requirements are met

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