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Results: 1-10 of 20

After months of anticipation, final FATCA regulations released

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2013

On January 17, 2013, the U.S. Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") issued final regulations2 implementing

IRS rolls out FATCA intergovernmental agreements

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

Since the United States announced an intergovernmental approach to FATCA compliance in its joint statement with five European countries earlier this

IRS issues final regulations on publicly traded property

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

On September 12, 2012, the IRS promulgated final regulations detailing when property will be treated as "publicly traded" for purposes of determining

Covered Bond Act amended by House Committee

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

On December 17, 2012, House Ways and Means Committee Chairman Dave Camp sent a letter to the House Committee on Financial Services ("HFSC"

IRS provides guidance to the field on economic substance for securities lending

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

On November 5, 2012, the IRS issued guidance to its field personnel regarding application of the common law economic substance doctrine to

CoCo development

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2013

2012 was an active year for issuers and investors in contingent convertible bonds or "CoCo"s. Most significantly in Q4 Barclays priced a $3 billion

U.S. Treasury and JapanSwitzerland announce they will negotiate toward a "third way" for FATCA compliance

  • Morrison & Foerster LLP
  • -
  • Japan, Switzerland, USA
  • -
  • July 9 2012

As we have previously reported, FATCA is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope

Draft Form W-8 released for FATCA implementation

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 9 2012

The IRS has released draft versions of revised Forms W-8 that allow foreign financial institutions (“FFIs”) to certify the status of beneficial accountholders that might otherwise be subject to withholding under FATCA

Redemption of trust preferreds following new Federal Reserve capital rules

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 9 2012

On June 7, 2012, the Federal banking agencies (the OCC, Federal Reserve Board and FDIC) (the “Agencies”) formally proposed for comment, in three separate but related proposals, significant changes to the U.S. regulatory capital framework: the Basel III Proposal, which applies the Basel III capital framework to almost all U.S. banking organizations; the Standardized Approach Proposal, which applies certain elements of the Basel II standardized approach for credit risk weightings to almost all U.S. banking organizations; and the Advanced Approaches Proposal, which applies changes made to Basel II and Basel III in the past few years to large U.S. banking organizations subject to the advanced Basel II capital framework

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

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2012

FATCA 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

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