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ARTICLE · 20 JUNE 2008

MoFo Tax Talk, Volume 1, Issue 2

Morrison Foerster
Morrison Foerster
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Morrison Foerster

Morrison Foerster

With approximately 1,000 lawyers in 19 offices, Morrison & Foerster is a preeminent global law firm...

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Issuances of hybrid and other Tier 1 instruments in Q2 have continued at a fast pace, with issuers raising capital in excess of $70 billion so far this calendar year.

United StatesTax
Thomas Humphreys
Thomas Humphreys
Lloyd Harmetz
Lloyd Harmetz
Shamir Merali
Shamir Merali
Anna Pinedo
Anna Pinedo
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Hybrids — An Update on Recent Mega Deals

Hybrids — Revenue Ruling 2003-97 in the News

Sovereign Wealth Funds — An Update

Credit Crunch Results in REMIC Relief

Auction Rate Securities — The IRS Provides For Liquidity

MoFo in the News

The Learning Annex: Demystifying Section 1260 (Constructive Ownership Transactions)

Developments in the Samurai Market

Variable Prepaid Forward Contracts Plus Share Loans — What if the IRS is Right?

Press Corner

Hybrids — An Update on Recent Mega Deals

Issuances of hybrid and other Tier 1 instruments in Q2 have continued at a fast pace, with issuers raising capital in excess of $70 billion so far this calendar year. The deals may be categorized into three baskets: long-term subordinated debt, payments on which are fully deductible by the issuer and taxed at ordinary rates to the holder; equity units which initially are partially

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