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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

Tax effect money market fund proposal

Morrison & Foerster LLP
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USA
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January 24 2013

There have been several proposals to reform the regulation of U.S. money market funds ("MMF"s) after the 2008 financial crisis. Some of the proposals

IRS issues final regulations on publicly traded property

Morrison & Foerster LLP
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USA
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January 24 2013

On September 12, 2012, the IRS promulgated final regulations detailing when property will be treated as "publicly traded" for purposes of determining

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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

Tax effect money market fund proposal

IRS issues final regulations on publicly traded property

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