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Results: 1-10 of 17

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


IRS issues guidance on when COD income is "qualifying income" for purposes of the publicly traded partnership provisions
  • Morrison & Foerster LLP
  • USA
  • July 9 2012

On June 15, 2012, the IRS issued guidance on when cancellation-of-indebtedness (“COD”) income is treated as “qualifying income” for purposes of determining whether publicly traded partnerships (“PTP”) must be treated as corporations under Section 7704


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


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


Morrison & Foerster quarterly news TaxTalk volume 6, No. 2 July 2013
  • Morrison & Foerster LLP
  • USA
  • July 22 2013

Recent federal securities law filings by two companies - one in the document management and storage business, the other an operator of data centers


Talk tax quarterly news
  • Morrison & Foerster LLP
  • USA
  • July 22 2011

Just as we were going to press bemoaning the impending January 1, 2013 effective date of the Foreign Account Tax Compliance Act, the Internal Revenue Service and Treasury Department announced an extension of the new provisions’ withholding and reporting requirements


Proposed bill seeks to modernize tax treatment of RICs
  • Morrison & Foerster LLP
  • USA
  • December 31 2009

Earlier this month, House Ways and Means Committee chairman, Charles Rangel (D-New York) introduced the Regulated Investment Company Modernization Act of 2009 ("Act"


SEC’s staff legal bulletin on legal opinions
  • Morrison & Foerster LLP
  • USA
  • November 8 2011

On October 14, 2011, the SEC staff published a legal bulletin (No. 19) that provides guidance on the legality and tax opinions (5.1 and 8.1 exhibits) filed in connection with securities offerings


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