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Results: 1-10 of 149

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


IRS unveils 2011 Offshore Voluntary Disclosure Initiative
  • Morrison & Foerster LLP
  • USA
  • February 14 2011

On February 8, 2011, the IRS unveiled the 2011 Offshore Voluntary Disclosure Initiative ("OVDI"), pursuant to which taxpayers may come forward, through August 31, 2011, to report previously undisclosed foreign accounts, assets, and income


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


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


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 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


IRS issues follow-up guidance on FATCA reporting and withholding requirements
  • Morrison & Foerster LLP
  • USA
  • April 20 2011

On April 8, 2011, the Internal Revenue Service ("IRS") and Treasury Department ("Treasury") issued Notice 2011-34 (the "Notice") setting forth additional guidance with respect to the reporting and withholding requirements under the Foreign Account Tax Compliance Act ("FATCA"