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Results: 1-10 of 25

DTC Announces New Eligibility Procedures for Section 871(m) Transactions
  • Morrison & Foerster LLP
  • USA
  • December 27 2016

In October 2016, The Depository Trust Company ("DTC") announced that it is adjusting its eligibility procedures to comply with Section 871(m) of the


IRS guidance on REMICs and REITs with respect to the Home Affordable Refinance Program
  • Morrison & Foerster LLP
  • USA
  • February 2 2012

In late December, the IRS issued guidance (Notice 2012-5 and Rev. Proc. 2012-14) that relaxed the real estate mortgage investment conduit (“REMIC”) and real estate investment trust (“REIT”) rules to accommodate refinanced “underwater” loans in Federal National Mortgage Association (“Fannie Mae”) and Federal Home Loan Mortgage Corporation (“Freddie Mac”) sponsored single family mortgagebacked securities


The classroom integrating a debt instrument with a hedge into a synthetic debt instrument
  • Morrison & Foerster LLP
  • USA
  • October 21 2011

Both issuers and holders of debt instruments may enter into hedging transactions in an effort to minimize or manage risk on such debt


Talk tax quarterly news
  • Morrison & Foerster LLP
  • USA
  • July 22 2011

Just as we were going to press bemoaning the impending January 1, 2013 effective date of the Foreign Account Tax Compliance Act, the Internal Revenue Service and Treasury Department announced an extension of the new provisions’ withholding and reporting requirements


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


Tax Talk: Volume 9, Issue 3, October, 2016
  • Morrison & Foerster LLP
  • USA
  • October 13 2016

On September 27, 2016, the IRS issued proposed regulations (the "Proposed Regulations") providing guidance relating to the income test and asset


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


A summary comparison of BDCs and REITs
  • Morrison & Foerster LLP
  • USA
  • October 2 2009

As we have discussed in our prior client alerts, BDCs and REITs have witnessed a resurgence of late


Morrison & Foerster quarterly news TaxTalk volume 6, No. 2 July 2013
  • Morrison & Foerster LLP
  • USA
  • July 22 2013

Recent federal securities law filings by two companies - one in the document management and storage business, the other an operator of data centers


IRS issues guidance on when COD income is "qualifying income" for purposes of the publicly traded partnership provisions
  • Morrison & Foerster LLP
  • USA
  • July 9 2012

On June 15, 2012, the IRS issued guidance on when cancellation-of-indebtedness (“COD”) income is treated as “qualifying income” for purposes of determining whether publicly traded partnerships (“PTP”) must be treated as corporations under Section 7704