We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 157

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


Treasury Expands Scope of REIT Spin-Off Rules in New Regulations
  • Morrison & Foerster LLP
  • USA
  • June 15 2016

On June 7, the Treasury Department released temporary regulations (the “Temporary Regulations”) that expand the types of spinoff transactions subject


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


Latest Treasury Action on Inversions Upends Pending Transactions and Surprises Many for Its Broad Scope and Use of Questionable Authority
  • Morrison & Foerster LLP
  • USA
  • April 19 2016

On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion


Proposed IRS Debt-Equity Regulations: Aimed at Post-Inversion “Earnings Stripping,” But May Also Impact Ordinary Related-Party Debt
  • Morrison & Foerster LLP
  • USA
  • April 12 2016

On April 4th, the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 385 which could


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


Extenders Bill Puts an End to Tax-Free REIT Spinoffs but Includes a Number of Favorable Changes to the Taxation of REITs
  • Morrison & Foerster LLP
  • USA
  • December 23 2015

On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law. Notably, the Act contains a number of substantive


Quick guide to REIT IPOs - 2015
  • Morrison & Foerster LLP
  • USA
  • November 30 2015

Real Estate Investment Trusts (“REITs”) are endlessly inventive. They were first developed in the 1960s as a means for ordinary retail investors to


Congress overhauls the partnership tax audit rules
  • Morrison & Foerster LLP
  • USA
  • November 6 2015

On November 2, 2015, President Obama signed the Bipartisan Budget Act of 2015 (the “Bill”), which repeals the TEFRA Unified Audit Procedures and


Tax talk - volume 8, No. 3, November 2015
  • Morrison & Foerster LLP
  • USA
  • November 3 2015

No one quite knows why, but in Q3 2015 the logjam broke on IRS guidance projects. Was it the September 17-19, 2015 ABA Tax section meeting in Chicago