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Results: 1-10 of 23

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


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


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


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


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 and Treasury release 2011- 2012 Priority Guidance Plan
  • Morrison & Foerster LLP
  • USA
  • October 21 2011

On September 2, 2011, the IRS and Treasury released the annual Priority Guidance Plan for 2011-2012 (the “Plan”), which contains 317 projects that are priorities for both agencies during the plan year (July 2011 through June 2012


The next chapter: A new bond linking financial returns to environmental or social goals could thrive. But securities law conditions need to be met first
  • Morrison & Foerster LLP
  • USA
  • September 12 2016

Shakespeare's Juliet may not have ascribed great significance to a name but for securities lawyers and market participants alike there is significance


Ninth Circuit affirms Samueli ruling
  • Morrison & Foerster LLP
  • USA
  • October 21 2011

On September 15, 2011, the United States Court of Appeals for the Ninth Circuit (the “Ninth Circuit”) held that the securities loan transaction at issue did not qualify for nonrecognition treatment as a securities loan under section 1058, affirming the March 16, 2009 Tax Court ruling, in Samueli v. Commissioner


Countdown to March 18, 2012: are you ready?
  • Morrison & Foerster LLP
  • USA
  • October 21 2011

Despite this summer’s extension of the FATCA withholding rules (scheduled to be phased-in over 2014 and 2015), FATCA’s next effective date (March 18, 2012) will continue to greatly impact global financial transactions


Recognition of unamortized hedge gain could not be deferred
  • Morrison & Foerster LLP
  • USA
  • October 21 2011

On September 2, 2011, the IRS issued a Chief Counsel Advice9 (the “CCA”) in which it concluded that a taxpayer could not defer gain from a hedge with respect to debentures repurchased at a discount by the taxpayer that elected to defer cancellation of debt (“COD”) income on such debentures