Remmelt Reigersman

Remmelt Reigersman

Morrison & Foerster LLP

Contact  |  View Bio  |  RSS

Latest Publications

Share:

MoFo Tax Talk: Volume 9, Issue 4

EDITOR’S NOTE - Tax Talk doesn’t remember much about 1985. But we do remember that, after Ronald Reagan was re-elected president in 1984, tax reform was a very hot topic (remember the Tax Reform Act of 1985?). Anyway,...more

2/13/2017 - Dividends FATCA Foreign Financial Institutions (FFI) Foreign Tax IRS REIT RICs Section 385 Section 871(m) Tax Reform

The Short Field Guide to IPOs - 2017

THE EMERGING GROWTH COMPANY - The JOBS Act created a new class of issuer: the emerging growth company (EGC). An EGC is defined as an issuer with total annual gross revenue of less than $1 billion during the most recent...more

1/5/2017 - Emerging Growth Companies Financial Reporting Foreign Private Issuers Initial Public Offerings IPO JOBS Act Public Offerings REIT Underwriting

Structured Thoughts: News for the financial services community - Special Issue

Final TLAC Rules and Structured Products - On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued its final rules regarding long-term debt and total loss absorbing...more

12/27/2016 - Depository Institutions EU EU Benchmark Regulation Fiduciary Rule FINRA Foreign Banks G-SIB Holding Companies IRS MiFID II Packaged Retail And Insurance-Based Investment Products (PRIIPS) Popular Regulatory Agenda Section 871(m) Structured Financial Products TLAC UK UK Brexit

IRS Provides Guidance on TLAC

On December 16, 2016, the Internal Revenue Service (“IRS”) issued Revenue Procedure 2017-12 (the “Revenue Procedure”), which provides that certain instruments issued by global systemically important banking organizations...more

12/22/2016 - Income Taxes IRS TLAC

Structured Thoughts: News for the financial services community, Volume 7, Issue 12

FDIC Adopts New Recordkeeping Requirements for Large Banks – Modifies Original Proposal as to Brokered CDs - In November 2016, the FDIC approved a final rule establishing recordkeeping requirements for insured...more

12/13/2016 - Banks Big Data DOL EU FDIC Fiduciary Rule FINRA Fixed Income Investments IRS MREL Recordkeeping Requirements SEC

IRS Guidance for Implementation of the Section 871(m) Regulations

On December 2, 2016, the Internal Revenue Service (“IRS”) released an advance version of Notice 2016-76 (the “Notice”) and followed through on its promise to provide taxpayers with guidance for complying with final and...more

12/6/2016 - Dividends Internal Revenue Code (IRC) IRS Qualified Derivatives Dealers (QDDs) Tax Liability

Quick Guide to REIT IPOs - 2016

Real Estate Investment Trusts (“REITs”) are endlessly inventive. They were first developed in the 1960s as a means for ordinary retail investors to hold interests in real estate. The REIT market has waxed and waned over the...more

11/18/2016 - CFTC Corporate Governance D&O Insurance Dodd-Frank Emerging Growth Companies Initial Public Offerings Mortgage REITS Registration Statement REIT Sarbanes-Oxley SEC

IRS Issues Final Debt-Equity Regulations

On October 13th, the Internal Revenue Service (“IRS”) followed through on its promise to issue final regulations and temporary regulations under Section1 385 (the “Final Regulations” and “Temporary Regulations,” respectively)...more

10/24/2016 - Credit Agreements Creditors Debt Instruments Debt-Equity Debtor-Creditor Disregarded Entities Enforcement Expanded Group Instruments (EGIs) IRS Proposed Regulation Rebuttable Presumptions

MoFo Tax Talk - Volume 9, No. 3

IRS Issues Proposed Regs on RIC Commodity Investments - On September 27, 2016, the IRS issued proposed regulations (the “Proposed Regulations”) providing guidance relating to the income test and asset diversification...more

10/13/2016 - Capital Gains CFCs Corporate Taxes Estate Tax Hillary Clinton Income Taxes IRS Marital Status PFIC Political Candidates Presidential Elections Proposed Regulation Registered Investment Companies (RICs) REIT TEFRA Trump Administration

MoFo Tax Talk - Volume 9, No. 2

Editor's Note - Welcome to Tax Talk 9.02. By this fall, we may look back on Q2 2016 with some nostalgia. Of course, there is the U.S. presidential election on November 8th, but U.S. tax advisors right now are more...more

8/8/2016 - Business Partners Disregarded Entities Grantor Trusts Insolvency Intermediary Agreements Internal Revenue Code (IRC) IRS Money Market Funds Partnerships REIT Safe Harbors SEC Self-Employment Tax Tax Reform

Practice Pointers on the Up-C Structure

In a structure commonly referred to as an “up-C,” an existing limited liability company or other partnership form (referred to here for convenience as “LLC”) undertakes a public offering through a newly formed corporation,...more

5/25/2016 - Common Stock Corporate Taxes Holding Companies Initial Public Offerings Limited Liability Company (LLC) Partnerships Private Equity Public Offerings REIT Up-C Entity Young Lawyers

MoFo Tax Talk - Volume 9, No. 1

IRS Publishes Proposed section 305(c) Regulations - On April 12th, the IRS published proposed regulations under Section 305(c) that address the treatment of deemed dividends to holders of stock and rights to acquire...more

5/9/2016 - Bad Boy Liability Bona Fide Purchaser Commodities Derivatives Diversity Jurisdiction Federal Taxes Investors IRS Political Candidates Presidential Elections REIT SCOTUS Student Loans

MoFo Tax Talk - Volume 8, No. 4

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more

2/3/2016 - Certiorari ConAgra Dividends FIRPTA Foreign Currency Income Taxes IRS Market Basket Political Candidates Protecting Americans from Tax Hikes (PATH) Act REIT RICs SCOTUS Tax Court Tax Refunds Withholding Tax

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 hold interests in real estate. The REIT market has waxed and waned over the...more

12/7/2015 - CFTC Corporate Governance D&O Insurance Dodd-Frank Emerging Growth Companies Initial Public Offerings Mortgage REITS Registration Statement REIT Sarbanes-Oxley SEC

Congress Overhauls the Partnership Tax Audit Rules

On November 2, 2015, President Obama signed the Bipartisan Budget Act of 2015 (the “Bill”), which repeals the TEFRA Unified Audit Procedures and replaces them with a radically modified “corporate” model for partnership tax...more

11/9/2015 - Audits Federal Budget IRS New Legislation Partnership Agreements Partnerships TEFRA

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, and Some Ugly

On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid under certain contracts as...more

9/22/2015 - Brokers Dividends Final Rules Hedges Internal Revenue Code (IRC) IRS Partnerships Withholding Tax

New IRS Guidance Limits Tax-Free Spin-Off Rulings – Implications for REIT Spin-Offs

On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more

9/18/2015 - Corporate Taxes Distribution Rules IRS New Guidance Private Letter Rulings REIT Revenue Procedures RICs Shareholders Spinoffs Tax-Free Transfers

MoFo Tax Talk - Volume 8, Issue 2

IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest - On Wednesday, July 8, the IRS released two notices addressing “basket contracts,”...more

8/7/2015 - De Minimus Quantity Exemption Derivatives Dodd-Frank Excise Tax FATCA IRS Life Insurance Partnerships Retrocession Contracts Senate Finance Committee Tax Court Tax Reform U.S. Treasury

Negative Interest Rate Consequences

Over the last few months, the financial press has been filled with reports of negative interest rates. For example, on December 18 2014, the Swiss National Bank announced that it would move from a zero percent interest rate...more

7/20/2015 - Amortization Bonds EU Foreign Issuers Income Taxes Interest Rates IRS Mortgage Lenders

The Best of a Bad Investment

A recent tax case out of the Fifth Circuit approved a taxpayer’s strategy to make the best of a bad investment. According to the facts of Pilgrim’s Pride v Commissioner, the taxpayer purchased preferred stock from two...more

5/8/2015 - Abandonment Income Taxes Investment Tax Credits IRS Stocks

MoFo Tax Talk Volume 8, Issue 1

In This Issue: - IRS Rules Debentures Are Part of Straddle; Interest Non-Deductible - Stock Abandonment Produces Ordinary Loss - Tax Consequences of Negative Interest Rates - Renewed Discussion of a...more

5/8/2015 - Corporate Taxes Debentures IRS Stocks

Morrison & Foerster Quarterly News Tax Talk - Volume 7, No.4 January 2015

In This Issue: - Congress Passes Year-End Tax Extenders Bill - House Adopts New “Dynamic Scoring” Rule - Foreign Fund Engaged in Lending and Stock Distribution Not Protected by “Trading in Stock or Securities”...more

2/20/2015 - Dividends Federal Taxes Limited Liability Company (LLC) REIT Safe Harbors Section 956

Tax Talk -- Volume 7, No. 3 -- November 2014

In This Issue: - IRS Clarifies Deadline for Correcting Withholding Documentation - Consent Payment Modifying Contingent Payment Debt Instrument Must be Tested for Significance - IRS Concludes Correction of Error...more

11/10/2014 - Commercial Bankruptcy Domestic Partnership Foreign Corporations Internal Revenue Code (IRC) IRS Legal Entities Transfer of Assets Withholding Requirements

Tax Talk -- Volume 7, No. 2 -- July 2014

In This Issue: - As FATCA Begins, IRS Rolls out Withholding Forms, Increases IGA Count - IRS Issues Final Circular 230 Rules Simplifying Written Tax Advice Requirements - Mortgage CCA Raises More...more

7/30/2014 - Accounting Banks Bitcoin FATCA FBAR Fees Intergovernmental Agreements IRS Merchant Fees Mortgages OVDP Proposed Regulation REIT Reporting Requirements Section 956 Securities Stock Options Tax Advice U.S. Treasury

38 Results
|
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×