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Thomas Humphreys

Thomas Humphreys

Morrison & Foerster LLP


Latest Publications

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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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