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Results: 11-20 of 89

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


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


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


Morrison & Foerster quarterly news TaxTalk volume 6, No. 2 July 2013
  • Morrison & Foerster LLP
  • USA
  • July 22 2013

Recent federal securities law filings by two companies - one in the document management and storage business, the other an operator of data centers


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


Proxy agreement no barrier to affiliated group membership
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

In a recent private letter ruling, the IRS addressed whether a wholly-owned subsidiary could be included in its parent's affiliated group, even


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


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


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