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Results: 1-10 of 149

Tax talk - volume 8, no. 2, August 2015
  • Morrison & Foerster LLP
  • USA
  • August 5 2015

It was only a matter of time before “transactions of interest” (“TOIs”) found their way to Wall Street. Way back in 2006, the IRS added a new


Tax talk - volume 7, no.4, January 2015
  • Morrison & Foerster LLP
  • USA
  • February 15 2015

Although 2015 is already under way, we can’t quite ring in the new year without sharing some of the more noteworthy tax items of Q4 2014 (and


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


After months of anticipation, final FATCA regulations released
  • Morrison & Foerster LLP
  • USA
  • January 29 2013

On January 17, 2013, the U.S. Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") issued final regulations implementing


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


CoCo development
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

2012 was an active year for issuers and investors in contingent convertible bonds or "CoCo"s. Most significantly in Q4 Barclays priced a $3 billion


Treasury releases FATCA intergovernmental model agreements
  • Morrison & Foerster LLP
  • USA
  • August 7 2012

On July 26, 2012, the U.S. Treasury Department (“Treasury”) released two model agreements that reflect the intergovernmental approach outlined in Treasury’s February joint statement with France, Germany, Italy, Spain, and the United Kingdom as an alternative to complying with the Foreign Account Tax Compliance Act (“FATCA”


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


FATCA registration begins
  • Morrison & Foerster LLP
  • USA
  • August 21 2013

On August 19, 2013, the Internal Revenue Service ("IRS") announced the opening of the Foreign Account Tax Compliance Act ("FATCA") registration


Tax talk - volume 7, no.3, November 2014
  • Morrison & Foerster LLP
  • USA
  • November 7 2014

We held up this issue of Tax Talk in hopes the November 4 U.S. midterm elections would clear up the political fog surrounding tax policy in