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Results: 1-10 of 139

Tax Talk - Volume 10, No. 2 August 2017
  • Morrison & Foerster LLP
  • European Union, United Kingdom, USA
  • August 11 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


Bank’s New York Office is Not a “Branch”
  • Morrison & Foerster LLP
  • USA
  • March 7 2017

A recent Advisory Opinion concluded that a non-U.S. banking organization's New York office did not meet the definition of a "branch" under former


Tax Talk - Volume 9, No. 4 February 2017
  • Morrison & Foerster LLP
  • OECD, United Kingdom, USA
  • February 13 2017

In case you haven't heard, Donald Trump is now president of the United States. Republicans now control the House, Senate, and Presidency. With this


IRS Provides Guidance on TLAC
  • Morrison & Foerster LLP
  • USA
  • December 27 2016

On December 16, 2016, the IRS issued a Revenue Procedure which provides that certain instruments issued by global systemically important banking


Tax Talk - Volume 9, No. 2, August 2016
  • Morrison & Foerster LLP
  • USA
  • August 5 2016

On April 4, 2016, the Treasury Department issued proposed regulations under Section 385 (the “Proposed Regulations”) which could dramatically change


New York City Tribunal Rejects City’s Attempt to Forcibly Combine Bank and Its Mortgage Subsidiary
  • Morrison & Foerster LLP
  • USA
  • June 6 2016

The New York City Tax Appeals Tribunal, affirming a determination of the Chief Administrative Law Judge, has held that Astoria Bank, which engaged in


New York City Tribunal Rejects City’s Attempt to Forcibly Combine Bank and Its Mortgage Subsidiary
  • Morrison & Foerster LLP
  • USA
  • May 26 2016

The New York City Tax Appeals Tribunal, affirming a determination of an Administrative Law Judge, has held that Astoria Bank, which engaged in a


New York State Releases New Corporate Tax Reform FAQs on Apportionment
  • Morrison & Foerster LLP
  • USA
  • May 4 2016

The New York State Department of Taxation and Finance continues to provide guidance in the form of responses to Frequently Asked Questions (“FAQs”


Tribunal Overturns ALJ and Holds That Bank Must Apply NOLs in Year Taxed on Non-Income Base
  • Morrison & Foerster LLP
  • USA
  • May 4 2016

The New York State Tax Appeals Tribunal has held that a taxpayer was required to use its net operating loss (“NOL”) carryforward deduction to


Tax Treatment of “Bad Boy Guarantees” Challenged by Recent IRS Memorandum
  • Morrison & Foerster LLP
  • USA
  • March 22 2016

A recently released legal memorandum by the Internal Revenue Service (IRS) Office of Chief Counsel, CCA 201606027 (the “Memorandum”), concluded that