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Results: 1-10 of 22

FACTA update: IRS releases new regulations, new forms, and new IGAs

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 17 2014

We can't think of a better way to end Q1 2014 than by bringing you the year's first issue of Tax Talk. Although Tax Talk is now in its seventh year

Tax Talk - Volume 6, No.3, October 2013

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 28 2013

As our readers are no doubt well aware, increasing political gridlock at the close of Q3 over the debt ceiling, among other points of Congressional

Reorganization plan qualifies for bankruptcy exception to NOL limitation rules

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2013

In another recent private letter ruling, the IRS ruled that an ownership change pursuant to a bankruptcy reorganization plan qualified for an

Ambac seeks bankruptcy court approval of settlement with government resolving dispute arising out of tax treatment of credit default swaps

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2013

On April 9, 2013, Ambac Financial Group, Inc. ("Ambac") submitted a proposed settlement with the United States to the U.S. Bankruptcy Court for the

Assessment of income from excess loss account barred

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

In LPCiminelli Interests, Inc. v. United States, the taxpayer sued the government to recover approximately $1.2 million in taxes paid. At issue in

Tax talk

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 17 2012

When U.S. voters go to the polls on November 6, they may not understand much about the respective candidates’ tax policies but that won’t be because Tax Talk didn’t try

NA General Partnership v. Commissioner addresses debt-equity characterization of related-party advances

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

In NA General Partnership v. Commissioner the Tax Court held that notes issued to a parent by a subsidiary in connection with the acquisition of a target were properly characterized as debt and were not equity for tax purposes

Tax Court recharacterizes preferred equity as debt in Hewlett-Packard case

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

In Hewlett-Packard Co. v. Commissioner, the Tax Court recharacterized preferred equity owned by Hewlett-Packard Co. (“HP”) in a Dutch corporation as indebtedness and denied HP foreign tax credits and a capital loss on the exit transaction

Second Circuit rejects GE capital deal, again

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

For the second time in six years, the U.S. Court of Appeals for the Second Circuit (the “Second Circuit”) rejected a GE Capital Corporation (“GECC”) transaction involving allocation of aircraft lease income to two Dutch banks

Tenth Circuit affirms Tax Court’s holding in Anschutz Co. v. Commissioner

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

In 2010, the Tax Court ruled against the taxpayer in Anschutz Company v. Commissioner, and held that a prepaid variable forward plus a stock loan is a sale for federal income tax purposes