Search results

Order by most recent / most popular / relevance

Results: 1-8 of 8

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

Another derivium capital case

Morrison & Foerster LLP
-
USA
-
April 18 2011

On April 4th the Tax Court decided another Derivium Capital case: Solleberger v. Comm’r, T.C. Memo 2011-78

Small Business Jobs Act affects source rules for guarantee fees

Morrison & Foerster LLP
-
USA
-
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
-
USA
-
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

Calloway v. Comm’r

Morrison & Foerster LLP
-
USA
-
July 16 2010

Calloway v. Comm’r, decided on July 8, 2010, in the Tax Court, held (i) that a purported non-recourse loan equal to 90 of the value of stock held by a taxpayer was, in substance, a sale for U.S. federal income tax purposes, and (ii) that the transaction was not a securities lending arrangement under Section 1058 of the Code

Summit v. Comm’r

Morrison & Foerster LLP
-
USA
-
July 16 2010

In Summitt v. Comm’r, 134 T.C. No. 12 (May 20, 2010) the Tax Court held that an over-the-counter foreign currency option was not a contract subject to Section 1256 of the Code, and accordingly, the taxpayer could not trigger the loss on a “majorminor currency” transaction by marking the foreign currency contract to market under Section 1256 of the Code