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Results: 1-10 of 141

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


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


IRS releases new FATCA Form
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

In the latest demonstration that the IRS is continuing to gear up for the implementation of FATCA, Draft Form 8957 has been released, which enables


House Ways & Means Committee proposal would require mark-to-market for derivatives and modify certain other tax rules
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

For many years, academics have proposed that the U.S. replace the current hodgepodge U.S. federal income tax rules applicable to financial


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


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


IRS rolls out FATCA intergovernmental agreements
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

Since the United States announced an intergovernmental approach to FATCA compliance in its joint statement with five European countries earlier this