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Results: 11-20 of 31

Recognition of unamortized hedge gain could not be deferred

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

On September 2, 2011, the IRS issued a Chief Counsel Advice9 (the “CCA”) in which it concluded that a taxpayer could not defer gain from a hedge with respect to debentures repurchased at a discount by the taxpayer that elected to defer cancellation of debt (“COD”) income on such debentures

IRS and Treasury release 2011- 2012 Priority Guidance Plan

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

On September 2, 2011, the IRS and Treasury released the annual Priority Guidance Plan for 2011-2012 (the “Plan”), which contains 317 projects that are priorities for both agencies during the plan year (July 2011 through June 2012

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

EU proposed financial transaction tax fortune or folly?

  • Morrison & Foerster LLP
  • -
  • European Union, United Kingdom
  • -
  • October 12 2011

Since the financial crisis, there has been frequent talk of the introduction of a financial transaction tax

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

Proposed regulations clarify and expand scope of “publicly traded”

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

The IRS released proposed regulations ("Proposed Regulations") on January 6, 2011, which clarify and expand the circumstances that cause property to be "publicly traded" for purposes of determining the issue price of a debt instrument

IRS characterizes unique “knock-out” option contract as direct ownership of underlying property

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • November 15 2010

On November 12, 2010, the Internal Revenue Service ("IRS") released an advice memorandum - AM 2010-005, dated October 15, 2010 - in which it concluded that a contract styled as an option should in substance be characterized for federal income tax purposes as direct ownership of the underlying property

Pending New York State proposal to tax non-residents on “carried” interests

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 2 2010

New York State Governor David A Patterson and the New York State legislature have each proposed separate revenue bills for New York State's fiscal year 20102011 which include substantial tax increases

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