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Results: 1-10 of 15

A summary comparison of BDCs and REITs

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 2 2009

As we have discussed in our prior client alerts, BDCs and REITs have witnessed a resurgence of late

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

The classroom integrating a debt instrument with a hedge into a synthetic debt instrument

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 21 2011

Both issuers and holders of debt instruments may enter into hedging transactions in an effort to minimize or manage risk on such debt

FACTA update: IRS releases new regulations, new forms, and new IGAs

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 17 2014

We can't think of a better way to end Q1 2014 than by bringing you the year's first issue of Tax Talk. Although Tax Talk is now in its seventh year

SEC’s staff legal bulletin on legal opinions

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • November 8 2011

On October 14, 2011, the SEC staff published a legal bulletin (No. 19) that provides guidance on the legality and tax opinions (5.1 and 8.1 exhibits) filed in connection with securities offerings

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

Ninth Circuit affirms Samueli ruling

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • 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

Proposed bill seeks to modernize tax treatment of RICs

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • 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"

IRS issues guidance on when COD income is "qualifying income" for purposes of the publicly traded partnership provisions

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • 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

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