We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 141

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


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


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


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


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


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


Congress considers financial transaction tax bill
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

So far, 2013 is proving to be a busy year for anyone trying to stay up-to-date on proposed changes to the tax code. One such change, the Wall Street


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