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IRS issues tech advice addressing restructured call options

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2012

In late October 2011, the IRS released a technical advice memorandum addressing whether written call options continued to be options for federal income tax purposes after being restructured, whether such restructuring of the options resulted in a Section2 1001 event, whether the restructured options were hedging transactions, and lastly whether the taxpayer was permitted to realize the options’ losses upon closing

Treasury releases temporary and proposed regulations on withholding under equity swaps

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • February 2 2012

On March 18, 2010, President Obama signed into law the Hiring Incentives to Restore Employment Act (the “Hire Act”

Proposed regulations would expand and clarify what contracts qualify as NPCs for tax purposes

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 21 2011

In response to the financial crisis, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd- Frank”) to, among other things, increase regulation of the capital markets

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

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