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Results: 1-10 of 22

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


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


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


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


Tax Talk: Volume 9, Issue 3, October, 2016
  • Morrison & Foerster LLP
  • USA
  • October 13 2016

On September 27, 2016, the IRS issued proposed regulations (the "Proposed Regulations") providing guidance relating to the income test and asset


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


IRS extends temporary guidance on REITRIC taxable stock dividends
  • Morrison & Foerster LLP
  • USA
  • December 23 2009

On December 23, 2009, under Revenue Procedure 2010-12, the Internal Revenue Service ("IRS") extended the period of temporary guidance regarding certain stock distributions by publicly-traded real estate investment trusts ("REITs") and regulated investment companies ("RICs"


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