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USA - March 31 2010 The US tax authorities will soon launch another prosecution against a foreign bank for facilitating offshore tax evasion, a la the case against Swiss bank UBS AG, according to an IRS agent speaking with Reuters....

Remmelt A. Reigersman, Anna T. Pinedo, Thomas A. Humphreys, Armin M. Gharagozlou.


Health Care Act revenue raisers

USA - March 31 2010 As discussed in our client alert, "Reconciliation Bill Codifies 'Economic Substance' Doctrine, Expands Medicare Taxes on High-Income Earners and Imposes Reporting Requirements on Certain Payments to Corporations," on March 30, 2010, President Barrack Obama signed into law the Health Care and Education Reconciliation Act of 2010, which supplements the Patient Protection and Affordable Care Act, which was signed into law on March 23, 2010....

Remmelt A. Reigersman, Anna T. Pinedo, Thomas A. Humphreys, Armin M. Gharagozlou.


Update on contingent capital

USA - March 31 2010 As we previously discussed in our prior issue of MoFo Tax Talk and elsewhere (see e.g., MoFo Tax Talk, Volume 2, Issue 4, “Contingent capital instruments,” and “Is it a bird? A plane? Exploring contingent capital”) contingent capital instruments are a novel hybrid security intended to provide a buffer for financial institution issuers during times of stress, when financial institutions may find it difficult to access the market in order to bolster their regulatory capital levels....

Remmelt A. Reigersman, Anna T. Pinedo, Thomas A. Humphreys, Armin M. Gharagozlou.


Container Corp. v. Commissioner: no US withholding tax on payment of guaranty fees by US subsidiary to foreign parent

USA - March 31 2010 In resolving what has long been an uncertain issue, the Tax Court held, in an opinion dated February 17, 2010, that a U.S. corporate subsidiary of a Mexican parent company was not required to withhold U.S. federal income taxes from the guaranty fees the subsidiary paid to its parent in connection with guaranteeing its debt....

Remmelt A. Reigersman, Anna T. Pinedo, Thomas A. Humphreys, Armin M. Gharagozlou.


The classroom: reopening structured notes

USA - March 31 2010 As discussed in our prior issue of MoFo Tax Talk (see MoFo Tax Talk, Volume 2, Issue 1), debt issues are often "reopened," meaning that an issuer issues an additional tranche of notes ("additional notes") at some point after the original issuance ("original notes")....

Remmelt A. Reigersman, Anna T. Pinedo, Thomas A. Humphreys, Armin M. Gharagozlou.