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Results: 1-10 of 34

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


IRS releases draft FFI Agreement
  • Morrison & Foerster LLP
  • USA
  • October 29 2013

On October 29, 2013, the Internal Revenue Service ("IRS") released Notice 2013-69 (the "Notice"), which includes a draft of the long-awaited "FFI


IRS lends public-private investment program a helping hand
  • Morrison & Foerster LLP
  • USA
  • October 2 2009

PPIP, unveiled on March 23, 2009, was designed to encourage the creation of markets for so-called "toxic assets" that were at the center of the credit crisis


Permissive guidance on commercial mortgage loan modifications
  • Morrison & Foerster LLP
  • USA
  • October 2 2009

On September 15, 2009, the IRS and the Treasury issued final regulations addressing permitted modifications of commercial mortgage loans held by a REMIC and Revenue Procedure 2009- 45, describing the conditions under which modifications to mortgage loans will not cause the IRS to challenge the tax status or treatment of securitization vehicles that hold the loans


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


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


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