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Results: 1-10 of 133

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

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

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

The classroom fixed-to-floaters

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

Fixed-to-floating rate notes appear to becoming more popular for fixed-income investors lately

IRS issuers private letter ruling on look-through approach for purposes of worthless stock deduction

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

With respect to a “security” that is a capital asset, a taxpayer is permitted to take a worthless security deduction if the security becomes worthless during the taxable year

IRS reverses its position on closing a forward with borrowed stock

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 18 2011

In Chief Counsel Advice 201104031 (the "CCA"), the IRS concluded that a variable prepaid forward contract settled with borrowed stock cannot be treated as an open transaction by the seller

IRS issues guidance on registered bonds days before repeal of bearer bond exception

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • March 9 2012

The Foreign Account Tax Compliance Act (“FATCA”), which was enacted as part of the Hiring Incentives to Restore Employment Act, ends the practice by U.S. issuers (and controlled foreign corporations) of selling bearer debt to foreign investors under “TEFRA C” and “TEFRA D” after March 18, 2012

Press corner

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

Taxes on sliced bagels?

Withholding on ADR fees

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 18 2011

In GLAM 2010-006, released December 17, 2010, the IRS concluded that payments by a domestic depositary institution (“DI”) to or on behalf of a foreign corporation for expenses of a sponsored American Depository Receipts (“ADR”) program are includible in the foreign corporation’s gross income and are subject to U.S. federal withholding tax

Medicare tax on the sale of a principal residence?

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

As discussed in our prior client alert, “Reconciliation Bill Codifies ‘Economic Substance’ Doctrine, Expands Medicare Taxes on High Income Earners and Imposes Reporting Requirements on Certain Payments to Corporations,” to pay for health care reform, among other revenue raisers, the Health Care Act introduced a 3.8 Medicare contribution tax (the “Medicare tax”) on unearned income (i.e., income other than from wages) of certain high income earners