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Results: 1-10 of 28

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

The Dodd-Frank Act

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 16 2010

Hybrids are Dead, Long Live Hybrids

IRS announces phased implementation of FACTA

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 19 2011

On July 14, 2011, the Internal Revenue Service (“IRS”) and Treasury Department (“Treasury”) announced a phase-in schedule which effectively delays implementation of the Foreign Account Tax Compliance Act (“FATCA”) for one year and, in some cases, until 2015

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

Treasury publishes highly anticipated “withholdable payment” FATCA regulations and outlines international cooperation alternative

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • February 14 2012

After months of waiting, the Treasury Department (“Treasury”) released proposed Foreign Account Tax Compliance Act (“FATCA”) “withholdable payment” regulations on February 8, 2012

IRS guidance on REMICs and REITs with respect to the Home Affordable Refinance Program

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

In late December, the IRS issued guidance (Notice 2012-5 and Rev. Proc. 2012-14) that relaxed the real estate mortgage investment conduit (“REMIC”) and real estate investment trust (“REIT”) rules to accommodate refinanced “underwater” loans in Federal National Mortgage Association (“Fannie Mae”) and Federal Home Loan Mortgage Corporation (“Freddie Mac”) sponsored single family mortgagebacked securities

Are you ready for March 18, 2012a key date in the U.S. taxation of cross-border financing transactions

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

We have previously discussed the significance of March 18, 2012 as the effective date of certain cross-border tax provisions included in the Foreign Account Tax Compliance Act (“FATCA”

IRS issues guidance on registered bonds days before repeal of bearer bond exception

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • March 9 2012

The Foreign Account Tax Compliance Act (“FATCA”), which was enacted as part of the Hiring Incentives to Restore Employment Act, ends the practice by U.S. issuers (and controlled foreign corporations) of selling bearer debt to foreign investors under “TEFRA C” and “TEFRA D” after March 18, 2012

IRS releases temporary and proposed regulations on reporting of specified foreign financial assets

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

In addition to the enactment of a new U.S. withholding regime, FATCA also included a new set of reporting requirements for specified foreign financial assets, currently residing in Section 6038D

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