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House Ways & Means Committee proposal would require mark-to-market for derivatives and modify certain other tax rules

Morrison & Foerster LLP
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USA
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April 30 2013

For many years, academics have proposed that the U.S. replace the current hodgepodge U.S. federal income tax rules applicable to financial

Moving from the academic to the legislative: House Ways & Means Committee proposal would require mark to market for derivatives and modify certain other tax rules applicable to financial instruments

Morrison & Foerster LLP
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USA
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February 11 2013

For many years, academics have proposed that the U.S. replace the current hodge-podge U.S. federal income tax rules applicable to financial

IRS issues tech advice addressing restructured call options

Morrison & Foerster LLP
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USA
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April 30 2012

In late October 2011, the IRS released a technical advice memorandum addressing whether written call options continued to be options for federal income tax purposes after being restructured, whether such restructuring of the options resulted in a Section2 1001 event, whether the restructured options were hedging transactions, and lastly whether the taxpayer was permitted to realize the options’ losses upon closing

Treasury releases temporary and proposed regulations on withholding under equity swaps

Morrison & Foerster LLP
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USA
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February 2 2012

On March 18, 2010, President Obama signed into law the Hiring Incentives to Restore Employment Act (the “Hire Act”

Proposed regulations would expand and clarify what contracts qualify as NPCs for tax purposes

Morrison & Foerster LLP
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USA
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October 21 2011

In response to the financial crisis, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd- Frank”) to, among other things, increase regulation of the capital markets

IRS publishes proposed regulations on swaps and notional principal contracts

Morrison & Foerster LLP
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USA
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September 21 2011

In response to the financial crisis, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) to, among other things, increase regulation of the capital markets

RIC commodity ruling update

Morrison & Foerster LLP
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USA
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August 2 2011

We learned last week that the Internal Revenue Service (“IRS”) has imposed an informal moratorium on private letter rulings for regulated investment companies (“RICs”) that invest in commodities through foreign subsidiaries or structured notes, presumably because the government is reconsidering the tax issues involved

Talk tax quarterly news

Morrison & Foerster LLP
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USA
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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

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

IRS issues Industry Director Directive on Total Return Swaps

Morrison & Foerster LLP
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USA
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March 31 2010

On January 14, 2010, the IRS issued an Industry Director Directive on Total Return Swaps Used to Avoid Dividend Withholding Tax ("IDD"

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