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Proposed bill seeks to modernize tax treatment of RICs

Morrison & Foerster LLP
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USA
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December 31 2009

Earlier this month, House Ways and Means Committee chairman, Charles Rangel (D-New York) introduced the Regulated Investment Company Modernization Act of 2009 ("Act"

Foreign Account Tax Compliance Act of 2009: proposed repeal of U.S. bearer bond exception

Morrison & Foerster LLP
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USA
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October 28 2009

On October 27, 2009, Senator Max Baucus (D-Montana) and Representative Charles Rangel (D-New York), chairmen of the Congressional tax writing committees, unveiled the Foreign Account Tax Compliance Act of 2009 (the "Bill"

Foreign Account Tax Compliance Act of 2009 United States to financial institutions: cooperate with anti-tax evasion efforts or else

Morrison & Foerster LLP
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USA
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October 29 2009

On October 27, 2009, Senator Max Baucus (D-Montana) and Representative Charles Rangel (D-New York), chairmen of the Congressional tax writing committees, introduced the Foreign Account Tax Compliance Act of 2009 (the “Bill”) in the U.S. Congress

IRS characterizes unique “knock-out” option contract as direct ownership of underlying property

Morrison & Foerster LLP
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USA
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November 15 2010

On November 12, 2010, the Internal Revenue Service ("IRS") released an advice memorandum - AM 2010-005, dated October 15, 2010 - in which it concluded that a contract styled as an option should in substance be characterized for federal income tax purposes as direct ownership of the underlying property

FinCEN and IRS extend certain FBAR filing deadlines

Morrison & Foerster LLP
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USA
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June 20 2011

During the past few weeks, the Financial Crimes Enforcement Network (“FinCEN”) and the Internal Revenue Service (“IRS”) released three notices affecting the filing of Form TD F 90-22.1 “Report of Foreign Bank and Financial Accounts” (“FBAR”), which are discussed below

Ninth Circuit affirms Samueli ruling

Morrison & Foerster LLP
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USA
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October 21 2011

On September 15, 2011, the United States Court of Appeals for the Ninth Circuit (the “Ninth Circuit”) held that the securities loan transaction at issue did not qualify for nonrecognition treatment as a securities loan under section 1058, affirming the March 16, 2009 Tax Court ruling, in Samueli v. Commissioner

Countdown to March 18, 2012: are you ready?

Morrison & Foerster LLP
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USA
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October 21 2011

Despite this summer’s extension of the FATCA withholding rules (scheduled to be phased-in over 2014 and 2015), FATCA’s next effective date (March 18, 2012) will continue to greatly impact global financial transactions

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

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

Morrison & Foerster LLP
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USA
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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 issues guidance on when COD income is "qualifying income" for purposes of the publicly traded partnership provisions

Morrison & Foerster LLP
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USA
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July 9 2012

On June 15, 2012, the IRS issued guidance on when cancellation-of-indebtedness (“COD”) income is treated as “qualifying income” for purposes of determining whether publicly traded partnerships (“PTP”) must be treated as corporations under Section 7704

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