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Holding the PHONE? equity linked debt instrument forms part of a straddle

Morrison & Foerster LLP
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USA
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April 30 2013

In a recent Chief Counsel Advice memorandum,17 the IRS concluded that equity-linked debt instruments issued by the Taxpayer, which referenced the

Proxy agreement no barrier to affiliated group membership

Morrison & Foerster LLP
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USA
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April 30 2013

In a recent private letter ruling, the IRS addressed whether a wholly-owned subsidiary could be included in its parent's affiliated group, even

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

Congress considers financial transaction tax bill

Morrison & Foerster LLP
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USA
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April 30 2013

So far, 2013 is proving to be a busy year for anyone trying to stay up-to-date on proposed changes to the tax code. One such change, the Wall Street

IRS releases new FATCA Form

Morrison & Foerster LLP
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USA
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April 30 2013

In the latest demonstration that the IRS is continuing to gear up for the implementation of FATCA, Draft Form 8957 has been released, which enables

House Ways & Means Committee proposal would require mark-to-market for derivatives and modify certain other tax rules

Morrison & Foerster LLP
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USA
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April 30 2013

For many years, academics have proposed that the U.S. replace the current hodgepodge U.S. federal income tax rules applicable to financial

After months of anticipation, final FATCA regulations released

Morrison & Foerster LLP
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USA
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April 30 2013

On January 17, 2013, the U.S. Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") issued final regulations2 implementing

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

FINRA’s Ketchum discusses structured products

Morrison & Foerster LLP
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USA
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April 26 2013

On April 9, 2013, Richard Ketchum, Chairman and Chief Executive Officer of FINRA, delivered a speech regarding the National Compliance Outreach

Update regarding TRACE Rule 144A securities

Morrison & Foerster LLP
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USA
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April 26 2013

In April 2013, FINRA's Board of Governors approved a proposal to publicly disseminate 144A transactions in TRACE-eligible securities for those asset

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Search results

Holding the PHONE? equity linked debt instrument forms part of a straddle

Proxy agreement no barrier to affiliated group membership

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

Congress considers financial transaction tax bill

IRS releases new FATCA Form

House Ways & Means Committee proposal would require mark-to-market for derivatives and modify certain other tax rules

After months of anticipation, final FATCA regulations released

Reorganization plan qualifies for bankruptcy exception to NOL limitation rules

FINRA’s Ketchum discusses structured products

Update regarding TRACE Rule 144A securities

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