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Results: 1-10 of 18

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


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


FACTA update: IRS releases new regulations, new forms, and new IGAs
  • Morrison & Foerster LLP
  • USA
  • April 17 2014

We can't think of a better way to end Q1 2014 than by bringing you the year's first issue of Tax Talk. Although Tax Talk is now in its seventh year


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


The classroom fixed-to-floaters
  • Morrison & Foerster LLP
  • USA
  • October 13 2010

Fixed-to-floating rate notes appear to becoming more popular for fixed-income investors lately


Proposed regulations clarify the definition of “real property” under the REIT rules
  • Morrison & Foerster LLP
  • USA
  • May 16 2014

On May 14, 2014, the Treasury Department published proposed regulations (the "Proposed Regulations") clarifying the definition of "real property"


Tax effect money market fund proposal
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

There have been several proposals to reform the regulation of U.S. money market funds ("MMF"s) after the 2008 financial crisis. Some of the proposals


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


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


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