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MOFO quaterly news - taxtalk - November 2014

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • November 7 2014

In CCA 201434021 (the "CCA"), the taxpayer was a withholding agent paying U.S.-source interest to nonresident aliens. In general, such interest

Tax talk - volume 7, no.3, November 2014

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • November 7 2014

We held up this issue of Tax Talk in hopes the November 4 U.S. midterm elections would clear up the political fog surrounding tax policy in

Notice 2014-46 provides additional guidance on eligibility of wind and other renewable energy facilities for the PTC or the ITC

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • August 18 2014

On August 8, 2014, the Internal Revenue Service (IRS) released Notice 2014-46 (the "Notice"), which provides some important clarifications with

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

The inversion craze: will today's routine tax planning be retroactively outlawed?

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 21 2014

Alongside the more typical summer fare, such as coverage of the best beach reading and the latest action movie blockbuster, this summer the media

Proposed regulations clarify the definition of “real property” under the REIT rules

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • May 16 2014

On May 14, 2014, the Treasury Department published proposed regulations (the "Proposed Regulations") clarifying the definition of "real property"

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