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Results: 1-10 of 31

IRS rolls out FATCA intergovernmental agreements

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

Since the United States announced an intergovernmental approach to FATCA compliance in its joint statement with five European countries earlier this

Redemption of trust preferreds following new Federal Reserve capital rules

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

On June 7, 2012, the Federal banking agencies (the OCC, Federal Reserve Board and FDIC) (the “Agencies”) formally proposed for comment, in three separate but related proposals, significant changes to the U.S. regulatory capital framework: the Basel III Proposal, which applies the Basel III capital framework to almost all U.S. banking organizations; the Standardized Approach Proposal, which applies certain elements of the Basel II standardized approach for credit risk weightings to almost all U.S. banking organizations; and the Advanced Approaches Proposal, which applies changes made to Basel II and Basel III in the past few years to large U.S. banking organizations subject to the advanced Basel II capital framework

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 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 provides guidance to the field on economic substance for securities lending

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

On November 5, 2012, the IRS issued guidance to its field personnel regarding application of the common law economic substance doctrine to

Covered Bond Act amended by House Committee

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

On December 17, 2012, House Ways and Means Committee Chairman Dave Camp sent a letter to the House Committee on Financial Services ("HFSC"

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

U.S. Treasury and JapanSwitzerland announce they will negotiate toward a "third way" for FATCA compliance

  • Morrison & Foerster LLP
  • -
  • Japan, Switzerland, USA
  • -
  • July 9 2012

As we have previously reported, FATCA is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope

Treasury releases FATCA intergovernmental model agreements

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • August 7 2012

On July 26, 2012, the U.S. Treasury Department (“Treasury”) released two model agreements that reflect the intergovernmental approach outlined in Treasury’s February joint statement with France, Germany, Italy, Spain, and the United Kingdom as an alternative to complying with the Foreign Account Tax Compliance Act (“FATCA”

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