We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
Lexology logo






  Request new password

Search results

Order by most recent / most popular / relevance

Results: 1-10 of 129

IRS releases new FATCA Form

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2013

In the latest demonstration that the IRS is continuing to gear up for the implementation of FATCA, Draft Form 8957 has been released, which enables

IRS rolls out FATCA intergovernmental agreements

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

Since the United States announced an intergovernmental approach to FATCA compliance in its joint statement with five European countries earlier this

Reorganization plan qualifies for bankruptcy exception to NOL limitation rules

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2013

In another recent private letter ruling, the IRS ruled that an ownership change pursuant to a bankruptcy reorganization plan qualified for an

After months of anticipation, final FATCA regulations released

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2013

On January 17, 2013, the U.S. Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") issued final regulations2 implementing

House Ways & Means Committee proposal would require mark-to-market for derivatives and modify certain other tax rules

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2013

For many years, academics have proposed that the U.S. replace the current hodgepodge U.S. federal income tax rules applicable to financial

Exploring the boundaries of variable rate debt instruments

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • December 31 2009

A complication that arises for floating rate-linked notes within the Type 1 category (i.e., principal protected notes treated as debt for U.S. federal income tax purposes) where the rate is expressed by reference to an index that does not measure borrowing rates (e.g., LIBOR or EURIBOR) is whether the expressed rate is treated as an objective rate within the meaning of the applicable regulations

Congress considers financial transaction tax bill

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2013

So far, 2013 is proving to be a busy year for anyone trying to stay up-to-date on proposed changes to the tax code. One such change, the Wall Street

Holding the PHONE? equity linked debt instrument forms part of a straddle

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2013

In a recent Chief Counsel Advice memorandum,17 the IRS concluded that equity-linked debt instruments issued by the Taxpayer, which referenced the

IRS technical advice: cumulative preferred stock that pays accumulated dividends at redemption is Section 1504(a)(4) preferred stock

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

A corporate taxpayer is generally entitled to a 70 percent dividends-received deduction with respect to dividends received from a domestic corporation

Repurchase premiums and consent fees

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 18 2011

In February, the IRS released a private letter ruling (PLR 201105016) addressing the federal income tax treatment of repurchase premium and consent fees in connection with the repurchase and modification of certain debt instruments issued by a corporate taxpayer

Current Search

Suggested Facets

Author

Jurisdiction

Workarea

© Copyright 2006-2013 Globe Business Publishing Ltd | Cookies | Disclaimer | Privacy policy