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Results: 1-10 of 34

IRS issues follow-up guidance on FATCA reporting and withholding requirements
  • Morrison & Foerster LLP
  • USA
  • April 20 2011

On April 8, 2011, the Internal Revenue Service ("IRS") and Treasury Department ("Treasury") issued Notice 2011-34 (the "Notice") setting forth additional guidance with respect to the reporting and withholding requirements under the Foreign Account Tax Compliance Act ("FATCA"


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


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


U.S. Treasury and JapanSwitzerland announce they will negotiate toward a third way for FATCA compliance
  • Morrison & Foerster LLP
  • Japan, Switzerland, USA
  • June 25 2012

As we have previously reported, the Foreign Account Tax Compliance Act (“FATCA”) is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope


Treasury publishes highly anticipated “withholdable payment” FATCA regulations and outlines international cooperation alternative
  • Morrison & Foerster LLP
  • USA
  • February 14 2012

After months of waiting, the Treasury Department (“Treasury”) released proposed Foreign Account Tax Compliance Act (“FATCA”) “withholdable payment” regulations on February 8, 2012


IRS issues guidance on registered bonds days before repeal of bearer bond exception
  • Morrison & Foerster LLP
  • USA
  • April 30 2012

FATCA 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