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Results: 1-10 of 31

Tax Talk - Volume 9, No. 2, August 2016
  • Morrison & Foerster LLP
  • USA
  • August 5 2016

On April 4, 2016, the Treasury Department issued proposed regulations under Section 385 (the “Proposed Regulations”) which could dramatically change


Tax Talk - Volume 9, No. 1, May 2016
  • Morrison & Foerster LLP
  • USA
  • May 6 2016

On April 12th, the IRS published proposed regulations under Section 305(c) that address the treatment of deemed dividends to holders of stock and


Tax talk - volume 8, No. 4, January 2016
  • Morrison & Foerster LLP
  • USA
  • January 4 2016

Q4 2015 saw one of the biggest tax bills to come along in some time. By all accounts, the “Protecting Americans from Tax Hikes,” or PATH Act, was a


Tax talk - volume 8, no. 2, August 2015
  • Morrison & Foerster LLP
  • USA
  • August 5 2015

It was only a matter of time before “transactions of interest” (“TOIs”) found their way to Wall Street. Way back in 2006, the IRS added a new


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