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Results: 1-10 of 134

IRS provides transitional relief from reporting obligations of corporate actions

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

Enacted as part of the Energy Improvement and Extension Act of 2008, Section 6045B provides that any domestic or foreign corporation (or entity treated as a corporation for federal income tax purposes) must file an information return with the IRS or publish on its website certain information if an organizational action (such as a stock split, a merger or an acquisition) affects the tax basis of any “specified security.”

The classroom: reopening structured notes

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • March 31 2010

As discussed in our prior issue of MoFo Tax Talk (see MoFo Tax Talk, Volume 2, Issue 1), debt issues are often "reopened," meaning that an issuer issues an additional tranche of notes ("additional notes") at some point after the original issuance ("original notes"

The handwriting is on the wall

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

In light of the proposed NPC regulations discussed in the prior piece, we noted with interest a comment by Steve Larson, IRS Associate Chief Counsel (Financial Institutions and Products) last week in New York reported in Tax Notes

FATCA provisions enacted into law - new withholding tax, ban on bearer bonds, and withholding on “dividend equivalents”

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • March 22 2010

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

Calloway v. Comm’r

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 16 2010

Calloway v. Comm’r, decided on July 8, 2010, in the Tax Court, held (i) that a purported non-recourse loan equal to 90 of the value of stock held by a taxpayer was, in substance, a sale for U.S. federal income tax purposes, and (ii) that the transaction was not a securities lending arrangement under Section 1058 of the Code

IRS rolls out FATCA intergovernmental agreements

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

Since the United States announced an intergovernmental approach to FATCA compliance in its joint statement with five European countries earlier this

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

From Extender’s Act to American Act to American jobs

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 16 2010

Representative Charles Rangel (D - New York) introduced the Tax Extenders Act of 2009 (the "Bill") on December 7, 2009

IRS issues economic substance “guidance”

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 13 2010

As we reported two issues ago in this publication, the "economic substance doctrine" has been codified

Redemption of trust preferreds following new Federal Reserve capital rules

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • 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