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Jack Cummings Alston & Bird LLP

Results 1 to 5 of 126



Limiting capitalization *

USA - May 13 2013
LTR 201319009 seems to be an odd ruling, because the taxpayer sought a ruling that it had to capitalize certain costs of an acquisition through use…


Proposed legislation and pending corporate guidance *

USA - May 1 2013
At a recent D.C Bar Tax Section Corporate Tax Committee meeting, panelists—including a Treasury representative—discussed some of the Administration’s…


The Supreme Court, federal taxation and the constitution *

USA - April 29 2013
In my recently published book, The Supreme Court, Federal Taxation and the Constitution, I review several constitutional issues that could impact the…


Supreme Court to review economic substance case *

USA - April 1 2013
United States v. Gary Woods, 471 Fed. Appx. 320 (5th Cir. 2012), affirming per curiam, 794 F. Supp. 2d 714 (WD Tex. 2011), will be reviewed by the…


The constitutionality of tax reform *

USA - March 1 2013
The Administration has indicated that it will pursue fundamental tax reform; leaders on the Hill have also indicated interest in doing so. Therefore…


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