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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


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


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


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


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


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 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


IRS rules that money market fund shares are "cash" for REIT asset test purposes
  • Morrison & Foerster LLP
  • USA
  • July 9 2012

On June 18, 2012, the IRS issued Revenue Ruling 2012-17, which addressed whether shares in a money market fund are categorized as “cash and cash items” for purposes of the 75 percent value test of Section 856


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