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

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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” Safe Harbor

- IRS Addresses Distribution by Corporation Electing to be Treated as REIT

- REIT Preferential Dividend

- Reporting Requirement for Payments to LLCs

- IRS Recharacterizes Offsetting Contracts

- IRS Applies Section 956 Anti-Abuse Rule (Again) to Recharacterize Backto- Back Loans

- IRS Revisits Prior Letter Rulings; Disapproves of “Costless Collar” Transaction

- PLI Webinar: Moving Away From The C-Corporation: Understanding REITs, MLPs, and PTPs

- MoFo in the News; Awards

- Excerpt from Congress Passes Year-End Tax Extenders Bill:

On December 19, just days before the end of 2014, President Obama signed into law the Tax Increase Prevention Act of 2014 (TIPA). TIPA retroactively extended a number of tax breaks for 2014 that had expired at the end of 2013. While we won’t bore our readers by reciting chapter and verse, there are a few key provisions of the tax extender’s bill worth mentioning. Specifically, taxpayers will still enjoy the benefit of the following tax breaks for 2014...

Please see full publication below for more information.

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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. Attorney Advertising.

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