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

Morrison & Foerster LLP
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USA
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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

Reorganization plan qualifies for bankruptcy exception to NOL limitation rules

Morrison & Foerster LLP
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USA
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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

Assessment of income from excess loss account barred

Morrison & Foerster LLP
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USA
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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
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USA
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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
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USA
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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
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USA
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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
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USA
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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
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USA
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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

Ninth Circuit affirms Samueli ruling

Morrison & Foerster LLP
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USA
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October 21 2011

On September 15, 2011, the United States Court of Appeals for the Ninth Circuit (the “Ninth Circuit”) held that the securities loan transaction at issue did not qualify for nonrecognition treatment as a securities loan under section 1058, affirming the March 16, 2009 Tax Court ruling, in Samueli v. Commissioner

Talk tax quarterly news

Morrison & Foerster LLP
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USA
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July 22 2011

Just as we were going to press bemoaning the impending January 1, 2013 effective date of the Foreign Account Tax Compliance Act, the Internal Revenue Service and Treasury Department announced an extension of the new provisions’ withholding and reporting requirements

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