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Results: 1-6 of 6

Legging-in and legging-out of an integrated transaction

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • February 2 2012

In the last edition of Tax Talk, our Classroom addressed integrating a debt instrument with a hedge into a synthetic debt instrument, where we reviewed the requirements in order to create a synthetic debt instrument under Section 1.1275-6.38

Talk tax quarterly news

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 22 2011

Just as we were going to press bemoaning the impending January 1, 2013 effective date of the Foreign Account Tax Compliance Act, the Internal Revenue Service and Treasury Department announced an extension of the new provisions’ withholding and reporting requirements

The classroom: reopening structured notes

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • March 31 2010

As discussed in our prior issue of MoFo Tax Talk (see MoFo Tax Talk, Volume 2, Issue 1), debt issues are often "reopened," meaning that an issuer issues an additional tranche of notes ("additional notes") at some point after the original issuance ("original notes"

“Enhanced” trust preferred securities: A-OK?

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 2 2009

On August 7, 2009, the IRS released Chief Counsel Memorandum 200932049 (the "Memorandum"), addressing the treatment of "trust preferred securities."

IRS lends public-private investment program a helping hand

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 2 2009

PPIP, unveiled on March 23, 2009, was designed to encourage the creation of markets for so-called "toxic assets" that were at the center of the credit crisis

Permissive guidance on commercial mortgage loan modifications

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 2 2009

On September 15, 2009, the IRS and the Treasury issued final regulations addressing permitted modifications of commercial mortgage loans held by a REMIC and Revenue Procedure 2009- 45, describing the conditions under which modifications to mortgage loans will not cause the IRS to challenge the tax status or treatment of securitization vehicles that hold the loans

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