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Searching Content indexed under Securitization & Structured Finance by Grant Thornton LLP ordered by Published Date Descending.
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Nonrecourse Debt Affects Mark-To-Market Calculation
The IRS concluded in an internal legal memorandum released Feb. 13 that a taxpayer’s nonrecourse liability affected its mark-to-market computation under Section 475(a).
United States
4 Mar 2015
2
IRS Rules That Interests In A Partnership And Trust Are Registered Obligations
Under Sections 871 and 881, interest must be paid on an obligation that is in registered form to qualify as portfolio interest.
United States
4 Mar 2015
3
IRS Concludes Taxpayer Was Securities Dealer
The IRS has concluded in a legal memorandum (ILM 2012-38-025) that a taxpayer was considered a dealer in securities under Section 475(c) because it purchased debt and subsequently sold such debt as part of its securitization activity.
United States
16 Oct 2012
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