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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

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 Talk - Volume 6, No.3, October 2013

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 28 2013

As our readers are no doubt well aware, increasing political gridlock at the close of Q3 over the debt ceiling, among other points of Congressional

Morrison & Foerster quarterly news TaxTalk volume 6, No. 2 July 2013

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 22 2013

Recent federal securities law filings by two companies - one in the document management and storage business, the other an operator of data centers

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

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

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 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

Proxy agreement no barrier to affiliated group membership

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

In a recent private letter ruling, the IRS addressed whether a wholly-owned subsidiary could be included in its parent's affiliated group, even

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