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Legging-in and legging-out of an integrated transaction

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • February 2 2012

In the last edition of Tax Talk, our Classroom addressed integrating a debt instrument with a hedge into a synthetic debt instrument, where we reviewed the requirements in order to create a synthetic debt instrument under Section 1.1275-6.38

The classroom fixed-to-floaters

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

Fixed-to-floating rate notes appear to becoming more popular for fixed-income investors lately

Talk tax quarterly news

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 22 2011

Just as we were going to press bemoaning the impending January 1, 2013 effective date of the Foreign Account Tax Compliance Act, the Internal Revenue Service and Treasury Department announced an extension of the new provisions’ withholding and reporting requirements

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