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Results: 1-10 of 133

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

IRS releases final and new proposed regulations that define “dividend equivalent” for U.S. withholding tax purposes

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • December 13 2013

On December 5, 2013, the Internal Revenue Service ("IRS") finalized temporary regulations and issued new proposed regulations under Section 871(m

IRS releases draft FFI Agreement

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 29 2013

On October 29, 2013, the Internal Revenue Service ("IRS") released Notice 2013-69 (the "Notice"), which includes a draft of the long-awaited "FFI

Tax Talk - Volume 6, No.3, October 2013

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 28 2013

As our readers are no doubt well aware, increasing political gridlock at the close of Q3 over the debt ceiling, among other points of Congressional

FATCA registration begins

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • August 21 2013

On August 19, 2013, the Internal Revenue Service ("IRS") announced the opening of the Foreign Account Tax Compliance Act ("FATCA") registration

Morrison & Foerster quarterly news TaxTalk volume 6, No. 2 July 2013

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 22 2013

Recent federal securities law filings by two companies - one in the document management and storage business, the other an operator of data centers

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

Reorganization plan qualifies for bankruptcy exception to NOL limitation rules

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

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

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