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MOFO quaterly news - taxtalk - July 2014

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 29 2014

With the halfway mark of 2014 just behind us, we are pleased to share with you in this issue of Tax Talk some of the more noteworthy tax developments

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

FACTA developments: Treasury concludes IGAS; IRS finalizes FFI Agreement

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2014

With 2013 rapidly coming to a close, the Government worked feverishly to conclude IGAs with a host of new countries, release a final version of the

After months of anticipation, final FATCA regulations released

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

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

IRS issues final regulations on publicly traded property

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

Covered Bond Act amended by House Committee

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

On December 17, 2012, House Ways and Means Committee Chairman Dave Camp sent a letter to the House Committee on Financial Services ("HFSC"

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

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

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