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141 results found

Article

Morrison & Foerster LLP | USA | 25 Apr 2019

Second Installment of Opportunity Zone Proposed Regulations Provide Additional Clarification and Guidance

On April 17, 2019, the U.S. Treasury Department and Internal Revenue Service issued a second installment of proposed regulations (the “Proposed

Article

Morrison & Foerster LLP | USA | 11 Jan 2019

Pennsylvania Says Receipts from Hedging Transactions Are Excluded from Sales Factor

On January 4, 2019, the Pennsylvania Department of Revenue issued Corporation Tax Bulletin 2019-01 taking the position that receipts from hedging

Article

Morrison & Foerster LLP | USA | 9 Nov 2018

New Section 956 Regulations Expand Scope of the New Participation Exemption But May Expose Borrowers to Increased Collateral Requirements

On October 31, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations that would limit the application of Section

Article

Morrison & Foerster LLP | USA | 24 Oct 2018

Massachusetts Proposes Changes to Manufacturing Corporation Regulation

The Massachusetts Department of Revenue (“Department”) recently promulgated a proposed amended regulation governing the classification of corporations

Article

Morrison & Foerster LLP | USA | 22 Oct 2018

Opportunity Zone Proposed Regulations Issued - Provide Much Needed Clarification and Guidance

On October 19, 2018, the U.S. Treasury Department and Internal Revenue Service (“IRS”) issued long-awaited and much anticipated proposed regulations

Article

Morrison & Foerster LLP | USA | 29 Aug 2018

IRS Issues Initial Guidance on Covered Employees and Grandfather Rule Under Amended Section 162(m)

On August 21, 2018, the Internal Revenue Service (the "IRS") issued Notice 2018-68 (the "Notice"), offering initial guidance on changes made to

Article

Morrison & Foerster LLP | USA | 27 Dec 2017

Notice Extends Phase-In of Section 871(m) Regulations

On August 4, 2017, the Internal Revenue Service released Notice 2017-42 (the "Notice"), which further extends the phase-in of regulations under

Article

Morrison & Foerster LLP | USA | 7 Dec 2017

Cryptocurrency Exchanges the New Front of the IRS War on Tax Evasion?

On November 29, 2017, the U.S. District Court for the Northern District of California dealt a partial blow to the U.S. Department of Justice and the

Article

Morrison & Foerster LLP | USA | 11 Sep 2017

Triple the risk, triple the uncertainty: tax False Claims Act suits.

During a single hearing in March 2016, a Cook County Circuit Judge dismissed over 200 False Claims Act ("FCA") suits brought by one qui tam relator in

Article

Morrison & Foerster LLP | USA | 3 Jun 2017

Section 871(m) Regulations: Changes Made by January 2017 Guidance

Section 871(m) is the Internal Revenue Code provision that treats "dividend equivalents" paid under certain contracts as dividends from sources within

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