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Tax effect money market fund proposal

Morrison & Foerster LLP
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USA
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January 24 2013

There have been several proposals to reform the regulation of U.S. money market funds ("MMF"s) after the 2008 financial crisis. Some of the proposals

IRS issues guidance on when COD income is "qualifying income" for purposes of the publicly traded partnership provisions

Morrison & Foerster LLP
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USA
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July 9 2012

On June 15, 2012, the IRS issued guidance on when cancellation-of-indebtedness (“COD”) income is treated as “qualifying income” for purposes of determining whether publicly traded partnerships (“PTP”) must be treated as corporations under Section 7704

IRS rules that money market fund shares are "cash" for REIT asset test purposes

Morrison & Foerster LLP
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USA
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July 9 2012

On June 18, 2012, the IRS issued Revenue Ruling 2012-17, which addressed whether shares in a money market fund are categorized as “cash and cash items” for purposes of the 75 percent value test of Section 856

IRS guidance on REMICs and REITs with respect to the Home Affordable Refinance Program

Morrison & Foerster LLP
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USA
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February 2 2012

In late December, the IRS issued guidance (Notice 2012-5 and Rev. Proc. 2012-14) that relaxed the real estate mortgage investment conduit (“REMIC”) and real estate investment trust (“REIT”) rules to accommodate refinanced “underwater” loans in Federal National Mortgage Association (“Fannie Mae”) and Federal Home Loan Mortgage Corporation (“Freddie Mac”) sponsored single family mortgagebacked securities

Ninth Circuit affirms Samueli ruling

Morrison & Foerster LLP
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USA
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October 21 2011

On September 15, 2011, the United States Court of Appeals for the Ninth Circuit (the “Ninth Circuit”) held that the securities loan transaction at issue did not qualify for nonrecognition treatment as a securities loan under section 1058, affirming the March 16, 2009 Tax Court ruling, in Samueli v. Commissioner

Countdown to March 18, 2012: are you ready?

Morrison & Foerster LLP
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USA
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October 21 2011

Despite this summer’s extension of the FATCA withholding rules (scheduled to be phased-in over 2014 and 2015), FATCA’s next effective date (March 18, 2012) will continue to greatly impact global financial transactions

Recognition of unamortized hedge gain could not be deferred

Morrison & Foerster LLP
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USA
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October 21 2011

On September 2, 2011, the IRS issued a Chief Counsel Advice9 (the “CCA”) in which it concluded that a taxpayer could not defer gain from a hedge with respect to debentures repurchased at a discount by the taxpayer that elected to defer cancellation of debt (“COD”) income on such debentures

IRS and Treasury release 2011- 2012 Priority Guidance Plan

Morrison & Foerster LLP
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USA
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October 21 2011

On September 2, 2011, the IRS and Treasury released the annual Priority Guidance Plan for 2011-2012 (the “Plan”), which contains 317 projects that are priorities for both agencies during the plan year (July 2011 through June 2012

The classroom integrating a debt instrument with a hedge into a synthetic debt instrument

Morrison & Foerster LLP
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USA
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October 21 2011

Both issuers and holders of debt instruments may enter into hedging transactions in an effort to minimize or manage risk on such debt

Talk tax quarterly news

Morrison & Foerster LLP
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USA
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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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