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Results: 1-10 of 31

A European financial transaction tax

  • Morrison & Foerster LLP
  • -
  • European Union
  • -
  • March 15 2013

In September 2011, the European Commission initially proposed that a financial transaction tax ("FTT") be implemented by all 27 EU Member States

IRS issues guidance on when COD income is "qualifying income" for purposes of the publicly traded partnership provisions

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

On June 15, 2012, the IRS issued guidance on when cancellation-of-indebtedness (“COD”) income is treated as “qualifying income” for purposes of determining whether publicly traded partnerships (“PTP”) must be treated as corporations under Section 7704

IRS rules that money market fund shares are "cash" for REIT asset test purposes

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

On June 18, 2012, the IRS issued Revenue Ruling 2012-17, which addressed whether shares in a money market fund are categorized as “cash and cash items” for purposes of the 75 percent value test of Section 856

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

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

The Foreign Account Tax Compliance Act (“FATCA”), which was enacted as part of the Hiring Incentives to Restore Employment Act, 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

Tribunal holds government financing agreements do not qualify as investment capital

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • February 2 2012

Reversing the decision of an Administrative Law Judge, the New York State Tax Appeals Tribunal has held that equipment financing agreements between Xerox Corporation and various governmental entities did not qualify as “investment capital,” and denied the refund sought by Xerox

IRS guidance on REMICs and REITs with respect to the Home Affordable Refinance Program

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • February 2 2012

In late December, the IRS issued guidance (Notice 2012-5 and Rev. Proc. 2012-14) that relaxed the real estate mortgage investment conduit (“REMIC”) and real estate investment trust (“REIT”) rules to accommodate refinanced “underwater” loans in Federal National Mortgage Association (“Fannie Mae”) and Federal Home Loan Mortgage Corporation (“Freddie Mac”) sponsored single family mortgagebacked securities

NYC implements new audit policy disallowing deductions by hedge fund managers

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 4 2012

The New York City Department of Finance has adopted a new a position on audits that could result in additional New York City unincorporated business tax (“UBT”) or general corporation tax (“GCT”) liabilities for hedge funds managers in New York City

SEC’s staff legal bulletin on legal opinions

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • November 8 2011

On October 14, 2011, the SEC staff published a legal bulletin (No. 19) that provides guidance on the legality and tax opinions (5.1 and 8.1 exhibits) filed in connection with securities offerings

Ninth Circuit affirms Samueli ruling

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

On September 15, 2011, the United States Court of Appeals for the Ninth Circuit (the “Ninth Circuit”) held that the securities loan transaction at issue did not qualify for nonrecognition treatment as a securities loan under section 1058, affirming the March 16, 2009 Tax Court ruling, in Samueli v. Commissioner

Countdown to March 18, 2012: are you ready?

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

Despite this summer’s extension of the FATCA withholding rules (scheduled to be phased-in over 2014 and 2015), FATCA’s next effective date (March 18, 2012) will continue to greatly impact global financial transactions

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