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Results: 1-10 of 151

Tax talk - volume 8, no. 1, May 2015
  • Morrison & Foerster LLP
  • USA
  • May 7 2015

Has anyone noticed how we’re in a seemingly endless discussion about tax reform? Ever since Representative Dave Camp (R. Mich.) issued his own tax


Tax me once
  • Morrison & Foerster LLP
  • USA
  • December 9 2014

For technology and other startups, going public can be doubly taxingliterally. “Traditionally, a pre-IPO company is structured as a C corporation


NA General Partnership v. Commissioner addresses debt-equity characterization of related-party advances
  • Morrison & Foerster LLP
  • USA
  • July 9 2012

In NA General Partnership v. Commissioner the Tax Court held that notes issued to a parent by a subsidiary in connection with the acquisition of a target were properly characterized as debt and were not equity for tax purposes


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


Tax Court recharacterizes preferred equity as debt in Hewlett-Packard case
  • Morrison & Foerster LLP
  • USA
  • July 9 2012

In Hewlett-Packard Co. v. Commissioner, the Tax Court recharacterized preferred equity owned by Hewlett-Packard Co. (“HP”) in a Dutch corporation as indebtedness and denied HP foreign tax credits and a capital loss on the exit transaction


U.S. Treasury and JapanSwitzerland announce they will negotiate toward a "third way" for FATCA compliance
  • Morrison & Foerster LLP
  • Japan, Switzerland, USA
  • July 9 2012

As we have previously reported, FATCA is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope


Draft Form W-8 released for FATCA implementation
  • Morrison & Foerster LLP
  • USA
  • July 9 2012

The IRS has released draft versions of revised Forms W-8 that allow foreign financial institutions (“FFIs”) to certify the status of beneficial accountholders that might otherwise be subject to withholding under FATCA


IRS advisory memo finds parent cannot claim subsidiary’s stock is worthless while tax refund is pending
  • Morrison & Foerster LLP
  • USA
  • July 9 2012

In May 2012, the IRS released an advisory memo addressing whether the parent of a consolidated group can claim a deduction for a subsidiary’s worthless stock when the subsidiary continues to hold tax refund claims


Tax talk
  • Morrison & Foerster LLP
  • USA
  • October 17 2012

When U.S. voters go to the polls on November 6, they may not understand much about the respective candidates’ tax policies but that won’t be because Tax Talk didn’t try


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