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Results: 1-10 of 115

Tribunal affirms ALJ decision rejecting increase in foreign bank’s allocation of income to New York State
  • Morrison & Foerster LLP
  • USA
  • July 13 2015

In Matter of UniCredit S.p.A., DTA No. 824103 (N.Y.S. Tax App. Trib., May 19, 2015), the New York State Tax Appeals Tribunal affirmed the decision of


State tax department outlines policy on transactions using virtual currency
  • Morrison & Foerster LLP
  • USA
  • January 5 2015

On the heels of Internal Revenue Service guidance addressing the federal tax consequences of using "convertible virtual currency," Notice 2014-21 (Mar


MoFo Tech - FallWinter 2014
  • Morrison & Foerster LLP
  • USA
  • October 6 2014

Within a decade, analysts say, the "Internet of Things" will have transformed our lives. Billions of Internet-connected devices will monitor our


MOFO quaterly news - taxtalk - July 2014
  • Morrison & Foerster LLP
  • USA
  • July 29 2014

With the halfway mark of 2014 just behind us, we are pleased to share with you in this issue of Tax Talk some of the more noteworthy tax developments


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


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


Mortgage finance company held subject to special assessment on generation of hazardous waste
  • Morrison & Foerster LLP
  • USA
  • January 6 2014

In Matter of DVL, Inc., DTA No. 824165 (N.Y.S. Div. of Tax App., Nov. 21, 2013), a New York State Administrative Law Judge ruled that a mortgage


ALJ rejects Department’s effort to increase a foreign bank’s allocation of income to New York State
  • Morrison & Foerster LLP
  • USA
  • December 2 2013

In Matter of Unicredit S.P.A., DTA No. 824013 (N.Y.S. Div. Of Tax App., Nov. 7, 2013), a New York State Administrative Law Judge rejected the


IRS releases draft FFI Agreement
  • Morrison & Foerster LLP
  • USA
  • October 29 2013

On October 29, 2013, the Internal Revenue Service ("IRS") released Notice 2013-69 (the "Notice"), which includes a draft of the long-awaited "FFI


State taxation of financial institutions
  • Morrison & Foerster LLP
  • USA
  • October 24 2013

Taxation of financial institutions is a complex and developing area. As the definitions of a "financial institution" are progressively broadened, a