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IRS: loan origination by foreign entity through U.S. intermediary subject to U.S. tax

Morrison & Foerster LLP
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USA
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September 25 2009

On September 22, 2009, the Office of Chief Counsel of the Internal Revenue Service ("IRS") released a generic legal advice memorandum ("Memorandum"), concluding that interest income earned by a foreign corporation with respect to loans originated by an agent in the U.S., whether dependent or independent, is subject to net income tax in the U.S. as income “effectively connected” with the conduct of a U.S. trade or business

Revenue Procedure 2010-14 new safe harbor for Code Section 1031 like-kind exchanges

Morrison & Foerster LLP
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USA
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March 5 2010

On March 5, 2010, the Internal Revenue Service ("IRS") issued Revenue Procedure 2010-14, providing a new safe harbor method of reporting gain or loss for certain taxpayers who enter into deferred like-kind exchanges under Section 1031 of the Internal Revenue Code ("Code") but fail to complete the exchange because a qualified intermediary defaults on its obligation to acquire and transfer replacement property

FATCA provisions enacted into law - new withholding tax, ban on bearer bonds, and withholding on “dividend equivalents”

Morrison & Foerster LLP
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USA
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March 22 2010

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

Health Care Act codifies “economic substance” doctrine, expands Medicare taxes on high-income earners, and imposes reporting requirements on certain payments to corporations

Morrison & Foerster LLP
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USA
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March 30 2010

On March 30, 2010, President Obama signed into law the Health Care and Education Reconciliation Act of 2010 which supplements the Patient Protection and Affordable Care Act which was signed into law on March 23, 2010 (together, the "Act"

IRS issues economic substance “guidance”

Morrison & Foerster LLP
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USA
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October 13 2010

As we reported two issues ago in this publication, the "economic substance doctrine" has been codified

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Morrison & Foerster LLP
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USA
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October 13 2010

Taxes on sliced bagels?

Medicare tax on the sale of a principal residence?

Morrison & Foerster LLP
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USA
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October 13 2010

As discussed in our prior client alert, “Reconciliation Bill Codifies ‘Economic Substance’ Doctrine, Expands Medicare Taxes on High Income Earners and Imposes Reporting Requirements on Certain Payments to Corporations,” to pay for health care reform, among other revenue raisers, the Health Care Act introduced a 3.8 Medicare contribution tax (the “Medicare tax”) on unearned income (i.e., income other than from wages) of certain high income earners

Small Business Jobs Act affects source rules for guarantee fees

Morrison & Foerster LLP
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USA
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October 13 2010

As discussed in our prior client alert "Small Business Jobs Act of 2010Key Revenue-Raising Provisions," the Small Business Jobs Act of 2010 (signed into law on September 27, 2010) includes $12 billion in tax cuts aimed at small businesses and several revenue raising provisions

Prepaid forward plus stock loan equals sale according to U.S. Tax Court

Morrison & Foerster LLP
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USA
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October 13 2010

On July 22, 2010, the U.S. Tax Court ruled against the taxpayer in Anschutz v. Comm’r, the widely followed U.S. prepaid forward plus stock loan case

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

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Search results

IRS: loan origination by foreign entity through U.S. intermediary subject to U.S. tax

Revenue Procedure 2010-14 new safe harbor for Code Section 1031 like-kind exchanges

FATCA provisions enacted into law - new withholding tax, ban on bearer bonds, and withholding on “dividend equivalents”

Health Care Act codifies “economic substance” doctrine, expands Medicare taxes on high-income earners, and imposes reporting requirements on certain payments to corporations

IRS issues economic substance “guidance”

Press corner

Medicare tax on the sale of a principal residence?

Small Business Jobs Act affects source rules for guarantee fees

Prepaid forward plus stock loan equals sale according to U.S. Tax Court

ISDA 2010 HIRE Act protocol

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