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Results: 1-10 of 138

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

IRS issues final regulations on publicly traded property

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

On September 12, 2012, the IRS promulgated final regulations detailing when property will be treated as "publicly traded" for purposes of determining

Covered Bond Act amended by House Committee

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

On December 17, 2012, House Ways and Means Committee Chairman Dave Camp sent a letter to the House Committee on Financial Services ("HFSC"

IRS provides guidance to the field on economic substance for securities lending

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

On November 5, 2012, the IRS issued guidance to its field personnel regarding application of the common law economic substance doctrine to

IRS proposes regulations on new Medicare tax

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

On December 5, 2012, the IRS published proposed regulations under Section 1411, addressing the new 3.8 percent Medicare tax on "net investment

IRS: loan origination by foreign entity through U.S. intermediary subject to U.S. tax

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • September 25 2009

On September 22, 2009, the Office of Chief Counsel of the Internal Revenue Service ("IRS") released a generic legal advice memorandum ("Memorandum"), concluding that interest income earned by a foreign corporation with respect to loans originated by an agent in the U.S., whether dependent or independent, is subject to net income tax in the U.S. as income “effectively connected” with the conduct of a U.S. trade or business

Schering-Plough Corp. v. United States

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 2 2009

In a 91-page opinion, a federal district court denied a refund claim by Schering-Plough Corp ("Schering") with respect to two transactions it had entered into almost two decades ago

Senator Ron Wyden’s “Oil Bill”

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 2 2009

On August 6, 2009, Senator Ron Wyden (D-Oregon) introduced the "Stop Tax-breaks for Oil Profiteering Act" in the Senate, which is intended to temporarily curb excessive speculative trading in the oil and gas futures markets by eliminating the preferential tax treatment of direct and certain derivative interests in oil and natural gas

Proposed bill seeks to modernize tax treatment of RICs

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • December 31 2009

Earlier this month, House Ways and Means Committee chairman, Charles Rangel (D-New York) introduced the Regulated Investment Company Modernization Act of 2009 ("Act"

U.S. continues to extend and expand relief through the Tax Code

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • December 31 2009

The Housing and Economic Recovery Act of 2008 provided a new refundable tax credit generally available for qualifying first-time homebuyers of a principal residence in the U.S