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Results: 1-10 of 166

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


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 releases final and new proposed regulations that define “dividend equivalent” for U.S. withholding tax purposes
  • Morrison & Foerster LLP
  • USA
  • December 13 2013

On December 5, 2013, the Internal Revenue Service ("IRS") finalized temporary regulations and issued new proposed regulations under Section 871(m


MOFO quaterly news - taxtalk - November 2014
  • Morrison & Foerster LLP
  • USA
  • November 7 2014

In CCA 201434021 (the "CCA"), the taxpayer was a withholding agent paying U.S.-source interest to nonresident aliens. In general, such interest


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


Tax Talk - Volume 6, No.3, October 2013
  • Morrison & Foerster LLP
  • USA
  • October 28 2013

As our readers are no doubt well aware, increasing political gridlock at the close of Q3 over the debt ceiling, among other points of Congressional


Using contingent consideration to bridge the value gap in acquisitions of publicly traded life science companies
  • Morrison & Foerster LLP
  • USA
  • February 25 2014

M&A activity remains in the doldrums as we enter 2014. According to FactSet Mergerstat, in 2013, 446 transactions were announced involving a U.S


Reorganization plan qualifies for bankruptcy exception to NOL limitation rules
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

In another recent private letter ruling, the IRS ruled that an ownership change pursuant to a bankruptcy reorganization plan qualified for an


Proxy agreement no barrier to affiliated group membership
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

In a recent private letter ruling, the IRS addressed whether a wholly-owned subsidiary could be included in its parent's affiliated group, even


Ambac seeks bankruptcy court approval of settlement with government resolving dispute arising out of tax treatment of credit default swaps
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

On April 9, 2013, Ambac Financial Group, Inc. ("Ambac") submitted a proposed settlement with the United States to the U.S. Bankruptcy Court for the