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FACTA developments: Treasury concludes IGAS; IRS finalizes FFI Agreement

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 24 2014

With 2013 rapidly coming to a close, the Government worked feverishly to conclude IGAs with a host of new countries, release a final version of the

Mortgage finance company held subject to special assessment on generation of hazardous waste

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 6 2014

In Matter of DVL, Inc., DTA No. 824165 (N.Y.S. Div. of Tax App., Nov. 21, 2013), a New York State Administrative Law Judge ruled that a mortgage

ALJ rejects Department’s effort to increase a foreign bank’s allocation of income to New York State

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • December 2 2013

In Matter of Unicredit S.P.A., DTA No. 824013 (N.Y.S. Div. Of Tax App., Nov. 7, 2013), a New York State Administrative Law Judge rejected the

IRS releases draft FFI Agreement

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 29 2013

On October 29, 2013, the Internal Revenue Service ("IRS") released Notice 2013-69 (the "Notice"), which includes a draft of the long-awaited "FFI

State taxation of financial institutions

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

Taxation of financial institutions is a complex and developing area. As the definitions of a "financial institution" are progressively broadened, a

Financial services report, summer 2013

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • June 5 2013

In Kilgore v. Keybank, N.A., the Ninth Circuit was poised to decide whether the Supreme Court’s Concepcion decision vitiates California’s “public”

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

“Grandfather” election after Gramm-Leach-Bliley continues despite corporate reorganization

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 4 2013

The Department of Taxation and Finance has ruled that a bank holding company that previously qualified to be taxed under Article 9-A under the New

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"