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Results: 1-10 of 25

Talk Talk - Volume 10, No. 1 May 2017
  • Morrison & Foerster LLP
  • USA
  • May 8 2017

On April 26, 2017, amidst much anticipation, the Trump administration released its tax plan, entitled “2017 Tax Reform for Economic Growth and


DTC Announces New Eligibility Procedures for Section 871(m) Transactions
  • Morrison & Foerster LLP
  • USA
  • December 27 2016

In October 2016, The Depository Trust Company ("DTC") announced that it is adjusting its eligibility procedures to comply with Section 871(m) of the


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


A summary comparison of BDCs and REITs
  • Morrison & Foerster LLP
  • USA
  • October 2 2009

As we have discussed in our prior client alerts, BDCs and REITs have witnessed a resurgence of late


Tax Talk - Volume 9, No. 4 February 2017
  • Morrison & Foerster LLP
  • OECD, United Kingdom, USA
  • February 13 2017

In case you haven't heard, Donald Trump is now president of the United States. Republicans now control the House, Senate, and Presidency. With this


The classroom integrating a debt instrument with a hedge into a synthetic debt instrument
  • Morrison & Foerster LLP
  • USA
  • October 21 2011

Both issuers and holders of debt instruments may enter into hedging transactions in an effort to minimize or manage risk on such debt


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


Quick Guide to REIT IPOs
  • Morrison & Foerster LLP
  • USA
  • November 17 2016

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


IRS releases notices designating certain “basket contracts” as listed transactions and others as reportable transactions of interest
  • Morrison & Foerster LLP
  • USA
  • August 31 2015

In July 2015, the IRS released two notices addressing "basket contracts." Generally, these are derivative instruments linked to a basket of reference


Tax Talk: Volume 9, Issue 3, October, 2016
  • Morrison & Foerster LLP
  • USA
  • October 13 2016

On September 27, 2016, the IRS issued proposed regulations (the "Proposed Regulations") providing guidance relating to the income test and asset