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IRS extends temporary guidance on REITRIC taxable stock dividends

Morrison & Foerster LLP
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USA
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December 23 2009

On December 23, 2009, under Revenue Procedure 2010-12, the Internal Revenue Service ("IRS") extended the period of temporary guidance regarding certain stock distributions by publicly-traded real estate investment trusts ("REITs") and regulated investment companies ("RICs"

Revenue Procedure 2010-14 new safe harbor for Code Section 1031 like-kind exchanges

Morrison & Foerster LLP
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USA
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March 5 2010

On March 5, 2010, the Internal Revenue Service ("IRS") issued Revenue Procedure 2010-14, providing a new safe harbor method of reporting gain or loss for certain taxpayers who enter into deferred like-kind exchanges under Section 1031 of the Internal Revenue Code ("Code") but fail to complete the exchange because a qualified intermediary defaults on its obligation to acquire and transfer replacement property

President Obama signs 2010 Tax Relief Act

Morrison & Foerster LLP
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USA
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December 17 2010

Today, President Obama signed the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the "Act") into law

IRS issues economic substance “guidance”

Morrison & Foerster LLP
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USA
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October 13 2010

As we reported two issues ago in this publication, the "economic substance doctrine" has been codified

Press corner

Morrison & Foerster LLP
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USA
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October 13 2010

Taxes on sliced bagels?

Medicare tax on the sale of a principal residence?

Morrison & Foerster LLP
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USA
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October 13 2010

As discussed in our prior client alert, “Reconciliation Bill Codifies ‘Economic Substance’ Doctrine, Expands Medicare Taxes on High Income Earners and Imposes Reporting Requirements on Certain Payments to Corporations,” to pay for health care reform, among other revenue raisers, the Health Care Act introduced a 3.8 Medicare contribution tax (the “Medicare tax”) on unearned income (i.e., income other than from wages) of certain high income earners

ISDA 2010 HIRE Act protocol

Morrison & Foerster LLP
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Global, USA
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October 13 2010

As discussed in more detail in a prior issue of MoFo Tax Talk, the HIRE Act treats as a U.S.-source dividend any “dividend equivalent” for purposes of U.S. withholding tax provisions

Did you catch that, again?

Morrison & Foerster LLP
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USA
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October 13 2010

In our first quarter 2010 issue, we included a piece entitled "Did You Catch That?", which addressed select provisions in new legislation that tinkered with (by increasing) the amount of estimated taxes that certain large corporations must pay over the course of a future year, effectively providing the government with a short-term loan

Small Business Jobs Act affects source rules for guarantee fees

Morrison & Foerster LLP
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USA
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October 13 2010

As discussed in our prior client alert "Small Business Jobs Act of 2010Key Revenue-Raising Provisions," the Small Business Jobs Act of 2010 (signed into law on September 27, 2010) includes $12 billion in tax cuts aimed at small businesses and several revenue raising provisions