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Results: 11-20 of 74

IRS provides guidance to the field on economic substance for securities lending

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

On November 5, 2012, the IRS issued guidance to its field personnel regarding application of the common law economic substance doctrine to

IRS proposes regulations on new Medicare tax

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

On December 5, 2012, the IRS published proposed regulations under Section 1411, addressing the new 3.8 percent Medicare tax on "net investment

Tax effect money market fund proposal

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • 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

CoCo development

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

2012 was an active year for issuers and investors in contingent convertible bonds or "CoCo"s. Most significantly in Q4 Barclays priced a $3 billion

IRS rolls out FATCA intergovernmental agreements

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

Since the United States announced an intergovernmental approach to FATCA compliance in its joint statement with five European countries earlier this

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

Fiscal cliff diving a.k.a. American Taxpayer Relief Act

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

On January 1, 2013, the Senate and the House of Representatives passed the American Taxpayer Relief Act of 2012 ("ATRA"), averting the so-called

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

Redemption of trust preferreds following new Federal Reserve capital rules

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

On June 7, 2012, the Federal banking agencies (the OCC, Federal Reserve Board and FDIC) (the “Agencies”) formally proposed for comment, in three separate but related proposals, significant changes to the U.S. regulatory capital framework: the Basel III Proposal, which applies the Basel III capital framework to almost all U.S. banking organizations; the Standardized Approach Proposal, which applies certain elements of the Basel II standardized approach for credit risk weightings to almost all U.S. banking organizations; and the Advanced Approaches Proposal, which applies changes made to Basel II and Basel III in the past few years to large U.S. banking organizations subject to the advanced Basel II capital framework

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

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