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.
The Foreign Account Tax Compliance Act (“FATCA”) legislation signed into law in March 2010 is designed to curb offshore tax evasion by U.S.
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
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.
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.
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.
On May 26, 2010, the SEC approved amendments to its Rule 15c2-12.
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.
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).
The Home Affordable Modification Program ("HAMP") was created as part of the Administration’s Financial Stability Plan, announced on February 10, 2009.