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Results: 11-20 of 83

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 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


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 effect money market fund proposal
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

There have been several proposals to reform the regulation of U.S. money market funds ("MMF"s) after the 2008 financial crisis. Some of the proposals


CoCo development
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

2012 was an active year for issuers and investors in contingent convertible bonds or "CoCo"s. Most significantly in Q4 Barclays priced a $3 billion