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Changes to Tax Guidance Provided in Response to the Market Turmoil  


Author:  Judith R. Fiorini.; Isaac J. Wheeler.


Source: Volume 27, Number 03, Spring 2010 , pp.43-56(14)




Journal of Taxation of Investments

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Abstract: 

In response to turmoil in the financial markets since 2008, the Internal Revenue Service and the Treasury Department have issued a number of notices and other guidance on the rules that apply to loans from foreign subsidiaries, net operating losses (NOLs) and other carry-forwards, auction rate securities, tax exempt bonds, dividends paid by real estate investment trusts (REITs) and regulated investment companies (RICs), and other matters.

Keywords: Period for Short-Term Lending; Definition of “Readily Marketable”; AHYDO Rules; Section 382—Loss Carryforwards; NOL Carryback Period; Auction Rate Securities; Stock Distributions by REITs and RICs; Tax-Exempt Bonds; REMICs and Fixed Investment

Affiliations:  1: Sullivan and Cromwell LLP; 2: Sullivan and Cromwell LLP.

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