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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

Fed eyes contingent capital

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

In the wake of the near collapse of the American banking system, much attention has been given to how to prevent a recurrence

IRS extends period of temporary relief to U.S. shareholders of CFCs

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 4 2010

On December 28, 2009, pursuant to Notice 2010-12, the Internal Revenue Service (“IRS”) extended the period of temporary relief to U.S. shareholders of controlled foreign corporations (“CFCs”) to facilitate liquidity

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

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

On September 22, 2009, the Office of Chief Counsel of the IRS released a generic legal advice memorandum, AM 2009-010 (“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

Tax Extenders Act of 2009 includes FATCA

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

In late October, Senator Max Baucus (D-Montana) and Representative Charles Rangel (D-New York), chairmen of the Congressional tax-writing committees, unveiled the Foreign Account Tax Compliance Act of 2009 ("FATCA"

Tax Extenders Act of 2009 includes updated FATCA tax on withholdable payments and revised ban on bearer bonds

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • December 8 2009

On December 7, 2009, U.S. House Ways and Means Committee Chairman Charles B. Rangel (D-New York) introduced H.R. 4213, the Tax Extenders Act of 2009 (the “Bill”

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

Exploring the boundaries of variable rate debt instruments

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

A complication that arises for floating rate-linked notes within the Type 1 category (i.e., principal protected notes treated as debt for U.S. federal income tax purposes) where the rate is expressed by reference to an index that does not measure borrowing rates (e.g., LIBOR or EURIBOR) is whether the expressed rate is treated as an objective rate within the meaning of the applicable regulations

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

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