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390 results found

Article

Alston & Bird LLP | USA | 27 Feb 2012

Reorganization and consolidated rulings issued

The usual Friday release of a large number of letter rulings by the IRS included several rulings of interest on reorganizations and consolidated return issues.

Article

Mayer Brown | USA | 2 Aug 2011

Foreign Account Tax Compliance Act

The Foreign Account Tax Compliance Act (“FATCA”) legislation signed into law in March 2010 is designed to curb offshore tax evasion by U.S.

Article

Fox Rothschild LLP | USA | 24 Jul 2011

Tax Court rules that securities transaction did not qualify under Section 1058: decision follows on the heels of the Tax Court's recent decisions under Section 1058 in anshutz (135 T.C. No.5) and Carroway (135 T.C. No. 3) decided last year

In Henry Samueli et al v. Commissioner, 132 T.C. No. 4 (2011), the Tax Court, per Judge Kroupa’s opinion for the majority, in response to the petitioners and respondent (IRS) filing of cross motions for summary judgment in a consolidated proceeding, upheld the Service’s deficiencies in income tax for denying the taxpayers interest deductions claimed on the underlying “margin loans” used to acquire the securities, were disallowed on the basis the purported payments of “interest” were not made with respect to an actual debt

Article

Orrick, Herrington & Sutcliffe LLP | Italy | 20 May 2011

Renegotiation of mortgage loans: the new provisions introduced by decree n. 1382011

On 5 May 2011 the Italian government approved the law-decree n. 138 containing urgent measures regarding economy (the "Development Decree"), which has not yet been published on the Official Gazette.

Article

Morrison & Foerster LLP | USA | 18 Jan 2011

Proposed regulations clarify and expand scope of “publicly traded”

The IRS released proposed regulations ("Proposed Regulations") on January 6, 2011, which clarify and expand the circumstances that cause property to be "publicly traded" for purposes of determining the issue price of a debt instrument.

Article

Morrison & Foerster LLP | USA | 10 Jan 2011

Proposed Treasury Regulations significantly clarify and expand scope of “publicly traded” for purposes of determining the issue

The Internal Revenue Service (the "IRS"), in proposed Treasury Regulations (REG-131947-10) (the "Proposed Regulations") released on January 6, 2011, clarifies and expands the circumstances that cause property to be "publicly traded" for purposes of determining the issue price of a debt instrument.

Article

Foley & Lardner LLP | USA | 16 Jun 2010

Rule 15c2-12: approved amendments effective December 1, 2010

On May 26, 2010, the SEC approved amendments to its Rule 15c2-12.

Article

Greenberg Traurig LLP | USA | 21 May 2010

When the other shoe falls: IRS Notice 2010-46 restricts the application of Notice 97-66 in advance of the effective date of Code 871(l)

Notice 97-661 created an opportunity for non-United States financial institutions to participate in the securities lending markets for stocks of U.S. corporations without suffering burdensome U.S. federal withholding taxes.

Article

Seyfarth Shaw LLP | USA | 29 Sep 2009

IRS announces new REMIC rules

On September 15, 2009, the United States Internal Revenue Service (IRS) released two significant pronouncements relating to modifications of loans held by real estate mortgage investment conduits (REMICs).

Article

Hunton Andrews Kurth LLP | USA | 23 Apr 2009

The “missing link” redux: update on Home Affordable Modification Program

The Home Affordable Modification Program ("HAMP") was created as part of the Administration’s Financial Stability Plan, announced on February 10, 2009.

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