MoFo Tax Talk - Volume 4, No. 2 - July 2011


In this issue: IRS Announces Phased Implementation of FATCA; The Gang of Six; IRS Issues Supplemental Guidance on FATCA Reporting and Withholding Requirements; IRS Temporarily Suspends Information Reporting Requirements; Third Circuit Affirms Schering-Plough Corp. Ruling in Merck & Co., Inc. v. U.S; Temporary and Proposed Regulations Issued on Transfer and Assignment of Derivative Contracts; Press Corner; and MoFo in the News.

Just as we were going to press bemoaning the impending January 1, 2013 effective date of the Foreign Account Tax Compliance Act (“FATCA”), the Internal Revenue Service (“IRS”) and Treasury Department (“Treasury”) announced an extension of the new provisions’ withholding and reporting requirements. We cover this “breaking news” in this issue along with other recent FATCA guidance. In other breaking news, we provide a brief summary of the tax provisions of the so-called “Gang of Six” deficit reduction plan. We also cover Merck & Co., Inc. v. U.S., in which the U.S. Court of Appeals for the Third Circuit (“Third Circuit”) affirmed the U.S. District Court’s denial of a refund claim with respect to the taxpayer’s assignment of interest rate swaps to its foreign subsidiaries in exchange for lump sum payments. Further, we cover the IRS’s temporary suspension of information reporting requirements enacted under the Hiring Incentives to Restore Employment Act (the “HIRE Act”). Finally, our regular features – Press Corner and MoFo in the News – are also included.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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