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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


New York City Tribunal Rejects City’s Attempt to Forcibly Combine Bank and Its Mortgage Subsidiary
  • Morrison & Foerster LLP
  • USA
  • June 6 2016

The New York City Tax Appeals Tribunal, affirming a determination of the Chief Administrative Law Judge, has held that Astoria Bank, which engaged in


New York City Tribunal Rejects City’s Attempt to Forcibly Combine Bank and Its Mortgage Subsidiary
  • Morrison & Foerster LLP
  • USA
  • May 26 2016

The New York City Tax Appeals Tribunal, affirming a determination of an Administrative Law Judge, has held that Astoria Bank, which engaged in a


Tribunal Overturns ALJ and Holds That Bank Must Apply NOLs in Year Taxed on Non-Income Base
  • Morrison & Foerster LLP
  • USA
  • May 4 2016

The New York State Tax Appeals Tribunal has held that a taxpayer was required to use its net operating loss (“NOL”) carryforward deduction to


New York State Releases New Corporate Tax Reform FAQs on Apportionment
  • Morrison & Foerster LLP
  • USA
  • May 4 2016

The New York State Department of Taxation and Finance continues to provide guidance in the form of responses to Frequently Asked Questions (“FAQs”


Tax Treatment of “Bad Boy Guarantees” Challenged by Recent IRS Memorandum
  • Morrison & Foerster LLP
  • USA
  • March 22 2016

A recently released legal memorandum by the Internal Revenue Service (IRS) Office of Chief Counsel, CCA 201606027 (the “Memorandum”), concluded that


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