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Results: 1-10 of 34

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"


IRS provides guidance to the field on economic substance for securities lending
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

On November 5, 2012, the IRS issued guidance to its field personnel regarding application of the common law economic substance doctrine to


Press corner
  • Morrison & Foerster LLP
  • USA
  • March 31 2010

The US tax authorities will soon launch another prosecution against a foreign bank for facilitating offshore tax evasion, a la the case against Swiss bank UBS AG, according to an IRS agent speaking with Reuters


IRS announces phased implementation of FACTA
  • Morrison & Foerster LLP
  • USA
  • July 19 2011

On July 14, 2011, the Internal Revenue Service (“IRS”) and Treasury Department (“Treasury”) announced a phase-in schedule which effectively delays implementation of the Foreign Account Tax Compliance Act (“FATCA”) for one year and, in some cases, until 2015


Talk tax quarterly news
  • Morrison & Foerster LLP
  • USA
  • July 22 2011

Just as we were going to press bemoaning the impending January 1, 2013 effective date of the Foreign Account Tax Compliance Act, the Internal Revenue Service and Treasury Department announced an extension of the new provisions’ withholding and reporting requirements


IRS issues guidance on registered bonds days before repeal of bearer bond exception
  • Morrison & Foerster LLP
  • USA
  • March 9 2012

The Foreign Account Tax Compliance Act (“FATCA”), which was enacted as part of the Hiring Incentives to Restore Employment Act, ends the practice by U.S. issuers (and controlled foreign corporations) of selling bearer debt to foreign investors under “TEFRA C” and “TEFRA D” after March 18, 2012


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