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Tax Talk - Volume 9, No. 4 February 2017
  • Morrison & Foerster LLP
  • OECD, United Kingdom, USA
  • February 13 2017

In case you haven't heard, Donald Trump is now president of the United States. Republicans now control the House, Senate, and Presidency. With this


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


MOFO quaterly news - taxtalk - July 2014
  • Morrison & Foerster LLP
  • USA
  • July 29 2014

With the halfway mark of 2014 just behind us, we are pleased to share with you in this issue of Tax Talk some of the more noteworthy tax developments


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


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


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


IRS issues final regulations on publicly traded property
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

On September 12, 2012, the IRS promulgated final regulations detailing when property will be treated as "publicly traded" for purposes of determining


Covered Bond Act amended by House Committee
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

On December 17, 2012, House Ways and Means Committee Chairman Dave Camp sent a letter to the House Committee on Financial Services ("HFSC"