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Results: 1-10 of 151

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


Morrison & Foerster quarterly news TaxTalk volume 6, No. 2 July 2013
  • Morrison & Foerster LLP
  • USA
  • July 22 2013

Recent federal securities law filings by two companies - one in the document management and storage business, the other an operator of data centers


Tax Extenders Act of 2009 includes updated FATCA tax on withholdable payments and revised ban on bearer bonds
  • Morrison & Foerster LLP
  • USA
  • December 8 2009

On December 7, 2009, U.S. House Ways and Means Committee Chairman Charles B. Rangel (D-New York) introduced H.R. 4213, the Tax Extenders Act of 2009 (the “Bill”


Proposed bill seeks to modernize tax treatment of RICs
  • Morrison & Foerster LLP
  • USA
  • December 31 2009

Earlier this month, House Ways and Means Committee chairman, Charles Rangel (D-New York) introduced the Regulated Investment Company Modernization Act of 2009 ("Act"


U.S. continues to extend and expand relief through the Tax Code
  • Morrison & Foerster LLP
  • USA
  • December 31 2009

The Housing and Economic Recovery Act of 2008 provided a new refundable tax credit generally available for qualifying first-time homebuyers of a principal residence in the U.S


Fed eyes contingent capital
  • Morrison & Foerster LLP
  • USA
  • December 31 2009

In the wake of the near collapse of the American banking system, much attention has been given to how to prevent a recurrence


IRS extends period of temporary relief to U.S. shareholders of CFCs
  • Morrison & Foerster LLP
  • USA
  • January 4 2010

On December 28, 2009, pursuant to Notice 2010-12, the Internal Revenue Service (“IRS”) extended the period of temporary relief to U.S. shareholders of controlled foreign corporations (“CFCs”) to facilitate liquidity


IRS memorandum: loan origination by foreign entity through U.S. intermediary subject to U.S. tax
  • Morrison & Foerster LLP
  • USA
  • December 31 2009

On September 22, 2009, the Office of Chief Counsel of the IRS released a generic legal advice memorandum, AM 2009-010 (“Memorandum”), concluding that interest income earned by a foreign corporation with respect to loans originated by an agent in the U.S., whether dependent or independent, is subject to net income tax in the U.S. as income “effectively connected” with the conduct of a U.S. trade or business


Tax Extenders Act of 2009 includes FATCA
  • Morrison & Foerster LLP
  • USA
  • December 31 2009

In late October, Senator Max Baucus (D-Montana) and Representative Charles Rangel (D-New York), chairmen of the Congressional tax-writing committees, unveiled the Foreign Account Tax Compliance Act of 2009 ("FATCA"


President Obama signs 2010 Tax Relief Act
  • Morrison & Foerster LLP
  • USA
  • December 17 2010

Today, President Obama signed the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the "Act") into law