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HIRE Act FACTA recap
- Morrison & Foerster LLP
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- USA
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- March 31 2010
As discussed in our prior client alert "FATCA Provisions Enacted Into Law: New Withholding Tax, Ban on Bearer Bonds, and Withholding on Dividend Equivalents," on March 18, 2010, President Obama signed into law the HIRE Act
IRS issues Industry Director Directive on Total Return Swaps
- Morrison & Foerster LLP
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- USA
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- March 31 2010
On January 14, 2010, the IRS issued an Industry Director Directive on Total Return Swaps Used to Avoid Dividend Withholding Tax ("IDD"
Did you catch that?
- Morrison & Foerster LLP
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- USA
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- March 31 2010
Keen readers of fine print may have noticed 561 of the HIRE Act and 1410 of the Health Care and Education Reconciliation Act of 2010
Container Corp. v. Commissioner: no US withholding tax on payment of guaranty fees by US subsidiary to foreign parent
- Morrison & Foerster LLP
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- USA
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- March 31 2010
In resolving what has long been an uncertain issue, the Tax Court held, in an opinion dated February 17, 2010, that a U.S. corporate subsidiary of a Mexican parent company was not required to withhold U.S. federal income taxes from the guaranty fees the subsidiary paid to its parent in connection with guaranteeing its debt
Press corner
- Morrison & Foerster LLP
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- USA
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- March 31 2010
The US tax authorities will soon launch another prosecution against a foreign bank for facilitating offshore tax evasion, a la the case against Swiss bank UBS AG, according to an IRS agent speaking with Reuters
The classroom: reopening structured notes
- Morrison & Foerster LLP
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- USA
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- March 31 2010
As discussed in our prior issue of MoFo Tax Talk (see MoFo Tax Talk, Volume 2, Issue 1), debt issues are often "reopened," meaning that an issuer issues an additional tranche of notes ("additional notes") at some point after the original issuance ("original notes"
Proposed bill seeks to modernize tax treatment of RICs
- Morrison & Foerster LLP
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- USA
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- December 31 2009
Earlier this month, House Ways and Means Committee chairman, Charles Rangel (D-New York) introduced the Regulated Investment Company Modernization Act of 2009 ("Act"
U.S. continues to extend and expand relief through the Tax Code
- Morrison & Foerster LLP
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- USA
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- December 31 2009
The Housing and Economic Recovery Act of 2008 provided a new refundable tax credit generally available for qualifying first-time homebuyers of a principal residence in the U.S
Tax Extenders Act of 2009 includes FATCA
- Morrison & Foerster LLP
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- USA
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- December 31 2009
In late October, Senator Max Baucus (D-Montana) and Representative Charles Rangel (D-New York), chairmen of the Congressional tax-writing committees, unveiled the Foreign Account Tax Compliance Act of 2009 ("FATCA"
IRS memorandum: loan origination by foreign entity through U.S. intermediary subject to U.S. tax
- Morrison & Foerster LLP
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- USA
- -
- December 31 2009
On September 22, 2009, the Office of Chief Counsel of the IRS released a generic legal advice memorandum, AM 2009-010 (“Memorandum”), concluding that interest income earned by a foreign corporation with respect to loans originated by an agent in the U.S., whether dependent or independent, is subject to net income tax in the U.S. as income “effectively connected” with the conduct of a U.S. trade or business
Current Search
- Firm Name - Morrison & Foerster LLP
- Author - Remmelt A. Reigersman
- Author - Anna T. Pinedo
- Author - Shamir Merali
- Workarea - Corporate Tax