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Results: 1-10 of 152

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


New IRS Guidance limits tax-free spin-off rulings implications for REIT spin-offs
  • Morrison & Foerster LLP
  • USA
  • September 17 2015

On September 14, 2015, the Internal Revenue Service ("IRS") issued Notice 2015-59 (the "Notice") and Revenue Procedure 2015-43 (the "Rev Proc"


Tax talk - volume 8, No. 4, January 2016
  • Morrison & Foerster LLP
  • USA
  • January 4 2016

Q4 2015 saw one of the biggest tax bills to come along in some time. By all accounts, the “Protecting Americans from Tax Hikes,” or PATH Act, was a


Up-C IPO tax considerations
  • Morrison & Foerster LLP
  • USA
  • October 20 2015

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Final and temporary dividend equivalent regulations issued some good, some bad, and some ugly
  • Morrison & Foerster LLP
  • USA
  • September 21 2015

On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m), the Internal Revenue Code


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


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


Fiscal cliff diving a.k.a. American Taxpayer Relief Act
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

On January 1, 2013, the Senate and the House of Representatives passed the American Taxpayer Relief Act of 2012 ("ATRA"), averting the so-called


Holding the PHONE? equity linked debt instrument forms part of a straddle
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

In a recent Chief Counsel Advice memorandum,17 the IRS concluded that equity-linked debt instruments issued by the Taxpayer, which referenced the