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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
Withholding on ADR fees
- Morrison & Foerster LLP
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- USA
- -
- 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enacted last year as part of the 2010 Patient Protection and Affordable Care Act (aka the "Healthcare Reform Bill") was repealed by Congress
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
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
Current Search
- Jurisdiction - USA
- Firm Name - Morrison & Foerster LLP
- Author - Remmelt A. Reigersman
- Author - Jared B. Goldberger
- Author - Anna T. Pinedo
- Author - Thomas A. Humphreys
- Author - Arthur Man