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Capital Markets Tax Quarterly 23 January 2019
As CMTQ hits the newsstands, a substantial part of the US government is on hold because of the failure to pass various appropriations bills for the 2019 fiscal year.
United States
28 Jan 2019
2
Capital Markets Tax Quarterly
Welcome to Mayer Brown's Capital Markets Tax Quarterly (CMTQ). This is a new publication for Mayer Brown's Tax practice, so let us explain what we're about.
United States
23 Oct 2018
3
IRS Rules Freddie Mac MBS Restructuring Does Not Trigger Gain Or Loss
Freddie Mac and Fannie Mae will cease issuing PCs and MBSs next year and switch to issuing Uniform Mortgage-Backed Securities ("UMBS") next year
United States
6 Sep 2018
4
Protecting Americans From Tax Hikes Act Of 2015: Effects On Taxation Of Investment In US Real Estate
On December 18, 2015, Congress passed and President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015.
United States
23 Dec 2015
5
Announcement 2012-42: Timelines For Due Diligence And Other Requirements Under FATCA
FFIs, grandfathered obligation On October 24, 2012, the Internal Revenue Service (IRS) and the US Department of Treasury (Treasury) issued "Announcement 2012-42: Timelines for Due Diligence and Other Requirements under FATCA" (the Announcement).
United States
2 Nov 2012
6
New Proposed Regulations Treat Credit Default Swaps As Notional Principal Contracts
The US Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "Service") issued proposed regulations on September 16, 2011 (the "proposed regulations") that, if finalized, will treat credit default swaps (CDSs) and certain other swaps as notional principal contracts (NPCs).
United States
14 Oct 2011
7
US IRS Issues Preliminary FATCA Guidance Establishing Due Diligence Procedures and Information Reporting Rules for Foreign Financial Institutions
On August 27, 2010, the US Internal Revenue Service (the "IRS") published Notice 2010-60 (the "Notice") containing preliminary guidance regarding implementation of the so-called FATCA rules.
United States
21 Sep 2010
8
Proposed Legislation Permits Foreign Shareholders to Own Increased Percentage of Domestic REITs Without Becoming Subject to FIRPTA
On July 30, 2010, the US House of Representatives passed H.R. 5901, the Real Estate Jobs and Investment Act of 2010, by a vote of 402 to 11.
United States
 
18 Aug 2010
9
Delaware Court Upholds Use of NOL Rights Plan
The Delaware Chancery Court’s recent decision in "Selectica, Inc. v. Versata Enterprises, Inc." approved the adoption and use of a shareholder rights plan specifically designed to protect a company’s net operating loss carryforwards ("NOLs").
United States
13 Mar 2010
10
House "Extenders" Provision Contains Modified Information Reporting and Withholding Tax Provisions First Proposed in the Foreign Account Tax Compliance Act of 2009
On December 9, 2009, as part of a package to extend certain expiring tax provisions, the US House of Representatives passed HR 4213 (the House Bill), a bill containing several of the international tax proposals first introduced in the Foreign Account Tax Compliance Act of 2009 (FATCA).
United States
15 Dec 2009
11
US Internal Revenue Service Provides Limited Extension of Time to File FBAR
A United States person with a financial interest in, or signature authority over, “foreign financial accounts,” may be required to file a “Report of Foreign Bank and Financial Accounts” (Form TD F 90-22.1, or “FBAR”).
United States
2 Jul 2009
12
US IRS Suggests Certain United States Persons with Ownership of Non-US Investment Vehicles May Need to File Report of Foreign Bank and Financial Accounts
Several US Internal Revenue Service (IRS) officials have recently indicated that TD F 90-22.1 (Report of Foreign Bank and Financial Accounts) (FBAR) should be filed by United States persons that own interests in certain non-US investment vehicles, such as hedge funds.
United States
25 Jun 2009
13
Hedge Funds, Real Estate Funds and Other Investment Funds Face Detrimental Tax Consequences from Proposed US Legislation
On March 2, 2009, Senator Carl Levin reintroduced a bill to the Senate and Representative Lloyd Doggett introduced a companion bill to the House, entitled the “Stop Tax Haven Abuse Act.”
United States
13 Mar 2009
14
2009 Economic Stimulus Package: Certain Debt Repurchases by Businesses Granted Relief from Tax on Cancellation of Indebtedneses Income
The economic stimulus package, signed into law on February 17, 2009, grants corporations and businesses that repurchase their debt at a discount a right, under certain circumstances, to elect to defer the recognition of their cancellation of indebtedness (COD) income for up to five years.
United States
24 Feb 2009
15
Year-End Deadline for Amending Deferred Compensation Plans And Legislation Limiting Deferrals by Non-US Funds
Many non-US investment funds (e.g., hedge funds and private equity funds) permit their investment managers to defer their management fees and other compensation (with a corresponding deferred recognition of taxable income).
United States
20 Oct 2008
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