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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
The classroom integrating a debt instrument with a hedge into a synthetic debt instrument
- Morrison & Foerster LLP
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- USA
- -
- October 21 2011
Both issuers and holders of debt instruments may enter into hedging transactions in an effort to minimize or manage risk on such debt
IRS guidance on REMICs and REITs with respect to the Home Affordable Refinance Program
- Morrison & Foerster LLP
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- USA
- -
- February 2 2012
In late December, the IRS issued guidance (Notice 2012-5 and Rev. Proc. 2012-14) that relaxed the real estate mortgage investment conduit (“REMIC”) and real estate investment trust (“REIT”) rules to accommodate refinanced “underwater” loans in Federal National Mortgage Association (“Fannie Mae”) and Federal Home Loan Mortgage Corporation (“Freddie Mac”) sponsored single family mortgagebacked securities
Recognition of unamortized hedge gain could not be deferred
- Morrison & Foerster LLP
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- USA
- -
- October 21 2011
On September 2, 2011, the IRS issued a Chief Counsel Advice9 (the “CCA”) in which it concluded that a taxpayer could not defer gain from a hedge with respect to debentures repurchased at a discount by the taxpayer that elected to defer cancellation of debt (“COD”) income on such debentures
NA General Partnership v. Commissioner addresses debt-equity characterization of related-party advances
- Morrison & Foerster LLP
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- USA
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- July 9 2012
In NA General Partnership v. Commissioner the Tax Court held that notes issued to a parent by a subsidiary in connection with the acquisition of a target were properly characterized as debt and were not equity for tax purposes
Redemption of trust preferreds following new Federal Reserve capital rules
- Morrison & Foerster LLP
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- USA
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- July 9 2012
On June 7, 2012, the Federal banking agencies (the OCC, Federal Reserve Board and FDIC) (the “Agencies”) formally proposed for comment, in three separate but related proposals, significant changes to the U.S. regulatory capital framework: the Basel III Proposal, which applies the Basel III capital framework to almost all U.S. banking organizations; the Standardized Approach Proposal, which applies certain elements of the Basel II standardized approach for credit risk weightings to almost all U.S. banking organizations; and the Advanced Approaches Proposal, which applies changes made to Basel II and Basel III in the past few years to large U.S. banking organizations subject to the advanced Basel II capital framework
U.S. Treasury and JapanSwitzerland announce they will negotiate toward a "third way" for FATCA compliance
- Morrison & Foerster LLP
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- Japan, Switzerland, USA
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- July 9 2012
As we have previously reported, FATCA is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope
IRS advisory memo finds parent cannot claim subsidiary’s stock is worthless while tax refund is pending
- Morrison & Foerster LLP
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- USA
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- July 9 2012
In May 2012, the IRS released an advisory memo addressing whether the parent of a consolidated group can claim a deduction for a subsidiary’s worthless stock when the subsidiary continues to hold tax refund claims
IRS and Treasury release 2011- 2012 Priority Guidance Plan
- Morrison & Foerster LLP
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- USA
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- October 21 2011
On September 2, 2011, the IRS and Treasury released the annual Priority Guidance Plan for 2011-2012 (the “Plan”), which contains 317 projects that are priorities for both agencies during the plan year (July 2011 through June 2012
Treasury publishes highly anticipated “withholdable payment” FATCA regulations and outlines international cooperation alternative
- Morrison & Foerster LLP
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- USA
- -
- April 30 2012
After months of waiting, the Treasury released proposed Foreign Account Tax Compliance Act (“FATCA”) “withholdable payment” regulations on February 8, 2012
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