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Results: 1-10 of 27

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


Tax talk - volume 7, no.4, January 2015
  • Morrison & Foerster LLP
  • USA
  • February 15 2015

Although 2015 is already under way, we can’t quite ring in the new year without sharing some of the more noteworthy tax items of Q4 2014 (and


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


FACTA update: IRS releases new regulations, new forms, and new IGAs
  • Morrison & Foerster LLP
  • USA
  • April 17 2014

We can't think of a better way to end Q1 2014 than by bringing you the year's first issue of Tax Talk. Although Tax Talk is now in its seventh year


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


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


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


Assessment of income from excess loss account barred
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

In LPCiminelli Interests, Inc. v. United States, the taxpayer sued the government to recover approximately $1.2 million in taxes paid. At issue in


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


NA General Partnership v. Commissioner addresses debt-equity characterization of related-party advances
  • Morrison & Foerster LLP
  • USA
  • July 9 2012

In NA General Partnership v. Commissioner the Tax Court held that notes issued to a parent by a subsidiary in connection with the acquisition of a target were properly characterized as debt and were not equity for tax purposes