Thomas Humphreys

Thomas Humphreys

Morrison & Foerster LLP

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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 Bitcoins 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

The Inversion Craze: Will Today's Routine Tax Planning Be Retroactively Outlawed?

Alongside the more typical summer fare, such as coverage of the best beach reading and the latest action movie blockbuster, this summer the media have been abuzz with seemingly daily reports on the latest so-called...more

7/22/2014 - AbbVie AstraZeneca Drug Manufacturers Inversion Manufacturers Medical Devices Medtronic Mylan Pharmaceuticals Offshore Companies Pfizer Pharmaceutical Retailers Tax Planning Walgreens

IRS Issues Final Circular 230 Rules Simplifying Written Advice Requirements

On June 9, 2014, the U.S. Treasury Department and Internal Revenue Service (“IRS”) issued final regulations replacing the “covered opinion” rules under Circular 230. Effective June 12, 2014, the final rules now subject all...more

7/10/2014 - Circular 230 Disclaimers Final Rules U.S. Treasury

Proposed Regulations Clarify the Definition of “Real Property” Under the REIT Rules

On May 14, 2014, the Treasury Department published proposed regulations (the “Proposed Regulations”) clarifying the definition of “real property” under the real estate investment trust (“REIT”) rules. The issuance of the...more

5/19/2014 - IRS Private Letter Rulings Property Tax REIT

Tax Talk -- Volume 7, No. 1 -- April 2014

In This Issue: - FATCA Update: IRS Releases New Regulations, New Forms, and New IGAs - No Rule Policy on MLPs - IRS Introduces New Grandfather Rule for Equity-Linked Instruments Under Section 871(m) - Rev....more

4/18/2014 - FATCA IGAs IRS MLPs Mortgage REITS REIT Safe Harbors

MoFo New York Tax Insights - Volume 6, No. 4 - January 2014

In This Issue: FATCA Developments: Treasury Signs IGAs; IRS Finalizes FFI Agreement; IRS Releases Final and New Proposed “Dividend Equivalent” Regs; IRS Issues Final Swap Assignment Regs; IRS Issues Final “Net...more

1/27/2014 - Capital Gains Capital Losses Dividends FFI IGAs Income Taxes IRS Net Investment Income REIT Stocks

IRS Releases Final and New Proposed Regulations That Define “Dividend Equivalent” for U.S. Withholding Tax Purposes

On December 5, 2013, the Internal Revenue Service (“IRS”) finalized temporary regulations and issued new proposed regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid...more

12/16/2013 - Dividends Income Taxes IRS Withholding Tax

MoFo’s Quick Guide to: REIT IPOs

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

12/6/2013 - IPO Real Estate Market Registration REIT SEC

Tax Talk -- Volume 6, No. 3 -- October 2013

In This Issue: A Primer on the Medical Device Excise Tax; FATCA Registration Begins; In re Downey Financial Corp. (U.S. Bankr. Court Dist. of Delaware 10/8/2013); In re NetBank (11th Cir. 9/10/2013); and In re...more

10/29/2013 - Affordable Care Act Excise Tax FATCA FDA IRS Medical Devices

FATCA Registration Begins

On August 19, 2013, the Internal Revenue Service (“IRS”) announced the opening of the Foreign Account Tax Compliance Act (“FATCA”) registration website (the “Portal”). The Portal, which was originally slated to open July 15,...more

8/22/2013 - FATCA IRS Registration Websites

Tax Talk -- Volume 6, No. 2 -- July 2013

In This Issue: IRS Leaves Potential REIT Conversions Hanging; IRS Proposes to Relax Wash Sale Rules for Floating NAV Money Market Fund Share Redemptions; IRS Confirms Mexican Land Trust Is Not Trust Under U.S. Tax Law;...more

7/23/2013 - Consumer Bankruptcy Conversion FATCA IGAs Income Taxes IRS Money Market Funds NAV REIT S-Corporation SEC Wash Sale Rules Wash Trades

IRS Delays FATCA Implementation

On July 12, 2013, the IRS released Notice 2013-43 (the “Notice”), which sets forth a revised timeline for the implementation of the Foreign Account Tax Compliance Act (“FATCA”). The most significant development is that...more

7/15/2013 - Delays FATCA Grandfathered Obligations IRS

Tax Talk -- Volume 6, No. 1 -- April 2013

In This Issue: House Ways & Means Committee Proposal Would Require Mark-to-Market for Derivatives and Modify Certain Other Tax Rules; After Months of Anticipation, Final FATCA Regulations Released; Congress Considers...more

4/30/2013 - Affiliates Credit Default Swaps Derivatives Equity Claims FATCA Financial Transaction Tax Forms Mark-To-Market Reorganizations

Moving from the Academic to the Legislative: House Ways & Means Committee Proposal Would Require Mark-to-Market for Derivatives...

BACKGROUND - For many years, academics have proposed that the U.S. replace the current hodge-podge U.S. federal income tax rules applicable to financial derivatives with a “mark-to-market” regime. In the first...more

2/20/2013 - Capital Gains Derivatives Hedging Income Taxes

After Months of Anticipation, Final FATCA Regulations Released

BACKGROUND - On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations implementing the Foreign Account Tax Compliance Act...more

1/30/2013 - Derivatives FATCA Foreign Investment HIRE Act Income Taxes IRS

Tax Talk -- Volume 5, No. 4 -- January 2013

In This Issue: Fiscal Cliff Diving a.k.a. American Taxpayer Relief Act; CoCo Developments; Tax Effect of Money Market Fund Proposals; IRS Issues Final Regulations on Publicly Traded Property; Assessment of Income from...more

1/28/2013 - American Taxpayer Relief Act FATCA Fiscal Cliff Income Taxes Intergovernmental Agreements IRS Medicare Taxes Money Market Funds Securities

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