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Talk tax quarterly news

Morrison & Foerster LLP
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USA
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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

Equity units exchange offer

Morrison & Foerster LLP
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USA
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April 18 2011

During the first quarter, the IRS issued PLR 201105030, addressing the repurchase by a corporate taxpayer of its outstanding equity units ("Units"

Proposed regulations for COD income exceptions

Morrison & Foerster LLP
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USA
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April 18 2011

The IRS issued proposed regulations providing guidance in applying the bankruptcy and insolvency exceptions for cancellation of debt ("COD") income to grantor trusts and disregarded entities

IRS reverses its position on closing a forward with borrowed stock

Morrison & Foerster LLP
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USA
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April 18 2011

In Chief Counsel Advice 201104031 (the "CCA"), the IRS concluded that a variable prepaid forward contract settled with borrowed stock cannot be treated as an open transaction by the seller

Withholding on ADR fees

Morrison & Foerster LLP
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USA
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April 18 2011

In GLAM 2010-006, released December 17, 2010, the IRS concluded that payments by a domestic depositary institution (“DI”) to or on behalf of a foreign corporation for expenses of a sponsored American Depository Receipts (“ADR”) program are includible in the foreign corporation’s gross income and are subject to U.S. federal withholding tax

Reporting obligations for corporate actions continued

Morrison & Foerster LLP
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USA
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April 18 2011

In the last edition of Tax Talk8 we discussed the new tax reporting obligations with respect to certain organizational actions (such as a stock split, a merger or an acquisition) affecting tax basis, effective as of January 1, 2011

Another derivium capital case

Morrison & Foerster LLP
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USA
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April 18 2011

On April 4th the Tax Court decided another Derivium Capital case: Solleberger v. Comm’r, T.C. Memo 2011-78

Repeal of expanded form 1099 information reporting requirement

Morrison & Foerster LLP
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USA
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April 18 2011

The expanded Form 1099 information reporting requirement enacted last year as part of the 2010 Patient Protection and Affordable Care Act (aka the "Healthcare Reform Bill") was repealed by Congress

Repurchase premiums and consent fees

Morrison & Foerster LLP
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USA
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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