We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search

Clear all

Refine your search

Tags

25 results found

Article

Morrison & Foerster LLP | USA, United Kingdom, European Union | 11 Aug 2017

Tax Talk - Volume 10, No. 2 August 2017

With the failure of health care legislation to “repeal and replace” the Affordable Care Act, eyes in Washington, D.C. are now turning to tax reform

Article

Morrison & Foerster LLP | USA | 30 Nov 2015

Quick guide to REIT IPOs - 2015

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

Article

Morrison & Foerster LLP | USA | 24 Jan 2013

IRS provides guidance to the field on economic substance for securities lending

On November 5, 2012, the IRS issued guidance to its field personnel regarding application of the common law economic substance doctrine to

Article

Morrison & Foerster LLP | USA | 9 Mar 2012

IRS issues guidance on registered bonds days before repeal of bearer bond exception

The Foreign Account Tax Compliance Act (“FATCA”), which was enacted as part of the Hiring Incentives to Restore Employment Act, ends the practice by U.S. issuers (and controlled foreign corporations) of selling bearer debt to foreign investors under “TEFRA C” and “TEFRA D” after March 18, 2012.

Article

Morrison & Foerster LLP | USA | 2 Feb 2012

Treasury releases temporary and proposed regulations on withholding under equity swaps

On March 18, 2010, President Obama signed into law the Hiring Incentives to Restore Employment Act (the “Hire Act”).

Article

Morrison & Foerster LLP | USA | 21 Oct 2011

Countdown to March 18, 2012: are you ready?

Despite this summer’s extension of the FATCA withholding rules (scheduled to be phased-in over 2014 and 2015), FATCA’s next effective date (March 18, 2012) will continue to greatly impact global financial transactions.

Article

Morrison & Foerster LLP | USA | 21 Oct 2011

Proposed regulations would expand and clarify what contracts qualify as NPCs for tax purposes

In response to the financial crisis, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd- Frank”) to, among other things, increase regulation of the capital markets.

Article

Morrison & Foerster LLP | USA | 21 Oct 2011

Ninth Circuit affirms Samueli ruling

On September 15, 2011, the United States Court of Appeals for the Ninth Circuit (the “Ninth Circuit”) held that the securities loan transaction at issue did not qualify for nonrecognition treatment as a securities loan under section 1058, affirming the March 16, 2009 Tax Court ruling, in Samueli v. Commissioner.

Article

Morrison & Foerster LLP | USA | 21 Sep 2011

IRS publishes proposed regulations on swaps and notional principal contracts

In response to the financial crisis, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) to, among other things, increase regulation of the capital markets.

Article

Morrison & Foerster LLP | USA | 2 Aug 2011

In re Lehman Brothers and principal protection

On July 27, 2011, Judge Lewis Kaplan issued a ruling in the case In re Lehman Brothers Securities and ERISA Litigation, in which the plaintiffs include pension funds, companies and individuals that were purchasers of various classes of equity and debt securities issued by Lehman Brothers Holdings Inc.

Previous page 1 2 3