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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 SEC’s report of its sweep examination of retail structured products
- Morrison & Foerster LLP
- -
- USA
- -
- August 2 2011
In this issue of Structured Thoughts, we discuss the SEC's report of its sweep examination of retail structured products, the RIC commodity ruling update, and In re Lehman Brothers and principal protection
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
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
The classroom: reopening structured notes
- Morrison & Foerster LLP
- -
- USA
- -
- 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"
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
“Enhanced” trust preferred securities: A-OK?
- Morrison & Foerster LLP
- -
- USA
- -
- October 2 2009
On August 7, 2009, the IRS released Chief Counsel Memorandum 200932049 (the "Memorandum"), addressing the treatment of "trust preferred securities."
IRS lends public-private investment program a helping hand
- Morrison & Foerster LLP
- -
- USA
- -
- October 2 2009
PPIP, unveiled on March 23, 2009, was designed to encourage the creation of markets for so-called "toxic assets" that were at the center of the credit crisis
Permissive guidance on commercial mortgage loan modifications
- Morrison & Foerster LLP
- -
- USA
- -
- October 2 2009
On September 15, 2009, the IRS and the Treasury issued final regulations addressing permitted modifications of commercial mortgage loans held by a REMIC and Revenue Procedure 2009- 45, describing the conditions under which modifications to mortgage loans will not cause the IRS to challenge the tax status or treatment of securitization vehicles that hold the loans
A primer on foreign-currency linked structured notes
- Morrison & Foerster LLP
- -
- Global
- -
- October 2 2009
Foreign-currency linked structured notes are a fast-growing segment of the structured products market
Current Search
- Firm Name - Morrison & Foerster LLP
- Author - Thomas A. Humphreys
- Workarea - Securitization & Structured Finance
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