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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


MOFO quaterly news - taxtalk - July 2014
  • Morrison & Foerster LLP
  • USA
  • July 29 2014

With the halfway mark of 2014 just behind us, we are pleased to share with you in this issue of Tax Talk some of the more noteworthy tax developments


FACTA developments: Treasury concludes IGAS; IRS finalizes FFI Agreement
  • Morrison & Foerster LLP
  • USA
  • January 24 2014

With 2013 rapidly coming to a close, the Government worked feverishly to conclude IGAs with a host of new countries, release a final version of the


Treasury publishes highly anticipated “withholdable payment” FATCA regulations and outlines international cooperation alternative
  • Morrison & Foerster LLP
  • USA
  • February 14 2012

After months of waiting, the Treasury Department (“Treasury”) released proposed Foreign Account Tax Compliance Act (“FATCA”) “withholdable payment” regulations on February 8, 2012


IRS issues guidance on registered bonds days before repeal of bearer bond exception
  • Morrison & Foerster LLP
  • USA
  • March 9 2012

The Foreign Account Tax Compliance Act (“FATCA”), which was enacted as part of the Hiring Incentives to Restore Employment Act, ends the practice by U.S. issuers (and controlled foreign corporations) of selling bearer debt to foreign investors under “TEFRA C” and “TEFRA D” after March 18, 2012


U.S. Treasury and JapanSwitzerland announce they will negotiate toward a third way for FATCA compliance
  • Morrison & Foerster LLP
  • Japan, Switzerland, USA
  • June 25 2012

As we have previously reported, the Foreign Account Tax Compliance Act (“FATCA”) is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope


IRS issues final regulations requiring reporting of deposit interest paid to non-resident aliens
  • Morrison & Foerster LLP
  • USA
  • April 23 2012

On April 17, 2012, the Internal Revenue Service (the “IRS”) issued final regulations requiring financial institutions to report to the IRS any payments of interest on deposits maintained at an office in the U.S. made to non-resident aliens who are residents of certain countries with which the U.S. has entered into exchange of information agreements


IRS issues tech advice addressing restructured call options
  • Morrison & Foerster LLP
  • USA
  • April 30 2012

In late October 2011, the IRS released a technical advice memorandum addressing whether written call options continued to be options for federal income tax purposes after being restructured, whether such restructuring of the options resulted in a Section2 1001 event, whether the restructured options were hedging transactions, and lastly whether the taxpayer was permitted to realize the options’ losses upon closing


IRS issues guidance on registered bonds days before repeal of bearer bond exception
  • Morrison & Foerster LLP
  • USA
  • April 30 2012

FATCA ends the practice by U.S. issuers (and controlled foreign corporations) of selling bearer debt to foreign investors under “TEFRA C” and “TEFRA D” after March 18, 2012


IRS offshore voluntary discosure program reopens
  • Morrison & Foerster LLP
  • USA
  • January 10 2012

On January 9, 2012, the Internal Revenue Service (the “IRS”) reopened indefinitely its offshore voluntary disclosure program (the “2012 OVDP”) to assist taxpayers in reporting undisclosed foreign accounts, assets, and income