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Results: 1-10 of 167

Tax talk - volume 7, no.3, November 2014
  • Morrison & Foerster LLP
  • USA
  • November 7 2014

We held up this issue of Tax Talk in hopes the November 4 U.S. midterm elections would clear up the political fog surrounding tax policy in


Quick Guide to REIT IPOs
  • Morrison & Foerster LLP
  • USA
  • November 17 2016

Real Estate Investment Trusts ("REITs") are endlessly inventive. They were first developed in the 1960s as a means for ordinary retail investors to


Fiscal cliff diving a.k.a. American Taxpayer Relief Act
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

On January 1, 2013, the Senate and the House of Representatives passed the American Taxpayer Relief Act of 2012 ("ATRA"), averting the so-called


Tax me once
  • Morrison & Foerster LLP
  • USA
  • December 9 2014

For technology and other startups, going public can be doubly taxingliterally. “Traditionally, a pre-IPO company is structured as a C corporation


Reorganization plan qualifies for bankruptcy exception to NOL limitation rules
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

In another recent private letter ruling, the IRS ruled that an ownership change pursuant to a bankruptcy reorganization plan qualified for an


Proxy agreement no barrier to affiliated group membership
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

In a recent private letter ruling, the IRS addressed whether a wholly-owned subsidiary could be included in its parent's affiliated group, even


Ambac seeks bankruptcy court approval of settlement with government resolving dispute arising out of tax treatment of credit default swaps
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

On April 9, 2013, Ambac Financial Group, Inc. ("Ambac") submitted a proposed settlement with the United States to the U.S. Bankruptcy Court for the


Congress considers financial transaction tax bill
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

So far, 2013 is proving to be a busy year for anyone trying to stay up-to-date on proposed changes to the tax code. One such change, the Wall Street


After months of anticipation, final FATCA regulations released
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

On January 17, 2013, the U.S. Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") issued final regulations2 implementing


Holding the PHONE? equity linked debt instrument forms part of a straddle
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

In a recent Chief Counsel Advice memorandum,17 the IRS concluded that equity-linked debt instruments issued by the Taxpayer, which referenced the