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Results: 1-10 of 16

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

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

FACTA update: IRS releases new regulations, new forms, and new IGAs

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 17 2014

We can't think of a better way to end Q1 2014 than by bringing you the year's first issue of Tax Talk. Although Tax Talk is now in its seventh year

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

Proposed regulations clarify the definition of “real property” under the REIT rules

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • May 16 2014

On May 14, 2014, the Treasury Department published proposed regulations (the "Proposed Regulations") clarifying the definition of "real property"

FACTA developments: Treasury concludes IGAS; IRS finalizes FFI Agreement

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2014

With 2013 rapidly coming to a close, the Government worked feverishly to conclude IGAs with a host of new countries, release a final version of the

Tax effect money market fund proposal

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

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

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

Ninth Circuit affirms Samueli ruling

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

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

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • 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 extends temporary guidance on REITRIC taxable stock dividends

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • December 23 2009

On December 23, 2009, under Revenue Procedure 2010-12, the Internal Revenue Service ("IRS") extended the period of temporary guidance regarding certain stock distributions by publicly-traded real estate investment trusts ("REITs") and regulated investment companies ("RICs"