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Results: 1-6 of 6

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 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

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

FinCEN and IRS extend certain FBAR filing deadlines

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

Modification of mortgage loansnew REIT safe harbor

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 18 2011

Acknowledging that the widespread decline in real estate values could adversely affect the ability of a REIT to maintain its status for federal income tax purposes, the IRS issued Revenue Procedure 2011-16 (the “Rev. Proc.”) on January 5, 2011 to provide REITs with relief from potential violations of the REIT qualification requirements that are due to certain modifications of mortgage loans

FinCEN and IRS provide timely FBAR guidance regarding key definitions

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • March 5 2010

Last week the Department of Treasury issued proposed regulations addressing key definitions related to the Report of Foreign Bank and Financial Accounts, commonly referred to as the "FBAR."

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