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Results: 1-10 of 24

U.S. Treasury and JapanSwitzerland announce they will negotiate toward a "third way" for FATCA compliance
  • Morrison & Foerster LLP
  • Japan, Switzerland, USA
  • July 9 2012

As we have previously reported, FATCA is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope


Draft Form W-8 released for FATCA implementation
  • Morrison & Foerster LLP
  • USA
  • July 9 2012

The IRS has released draft versions of revised Forms W-8 that allow foreign financial institutions (“FFIs”) to certify the status of beneficial accountholders that might otherwise be subject to withholding under FATCA


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


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


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 guidance on REMICs and REITs with respect to the Home Affordable Refinance Program
  • Morrison & Foerster LLP
  • USA
  • February 2 2012

In late December, the IRS issued guidance (Notice 2012-5 and Rev. Proc. 2012-14) that relaxed the real estate mortgage investment conduit (“REMIC”) and real estate investment trust (“REIT”) rules to accommodate refinanced “underwater” loans in Federal National Mortgage Association (“Fannie Mae”) and Federal Home Loan Mortgage Corporation (“Freddie Mac”) sponsored single family mortgagebacked securities


IRS releases temporary and proposed regulations on reporting of specified foreign financial assets
  • Morrison & Foerster LLP
  • USA
  • February 2 2012

In addition to the enactment of a new U.S. withholding regime, FATCA also included a new set of reporting requirements for specified foreign financial assets, currently residing in Section 6038D


IRS private letter ruling: conversion of bonds to a new interest rate period is not a significant modification
  • Morrison & Foerster LLP
  • USA
  • February 2 2012

In a recent private letter ruling, the IRS addressed the debt modification regulations


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