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John Baron Alston & Bird LLP

Results 1 to 5 of 5

Federal tax crimes *

USA - April 1 2014
Few taxpayers are aware of the operations of the Criminal Investigation Division of the IRS, and rightly so. Out of hundreds of millions of tax…

Co-authors: Sam K. Kaywood , Jr, Henry J. Birnkrant , James E. Croker , Jr, Edward Tanenbaum, George Abney.

REMIC tax concerns surrounding foreclosures *

USA - March 6 2012
A Real Estate Mortgage Investment Conduit (REMIC) is an entity employed to securitize loans secured by real property and that has been granted tax-favored status.

Co-authors: Robert J. Sullivan.

Standard & Poor’s revises criteria for collateral for U.S. CMBS defeasances in response to U.S. debt downgrade *

USA - August 18 2011
As an immediate consequence of Standard & Poor’s recent downgrade of the U.S. sovereign longterm debt rating from AAA to AA+, the defeasance industry was almost brought to a standstill as the U.S treasuries that are typically utilized as collateral in defeasances transactions no longer met S&P’s defeasance guidelines.

Co-authors: Paul S. Donohue.

Expensing royalty fees *

USA - May 1 2010
This recent decision allowed the immediate deduction of license royalty payments as they accrued on the sale of the licensed inventory, rather than requiring the royalties to be capitalized into inventory.

Co-authors: Clay Littlefield.

IRS will not challenge REMIC status for certain loan modifications made in connection with the Home Affordable Modification Program *

USA - April 13 2009
On April 10, 2009, the Internal Revenue Service (IRS) issued Revenue Procedure 2009-23 (the "Revenue Procedure") and Notice 2009-36 (the "Notice"), to provide guidance regarding the effects of the Home Affordable Modification Program (HAMP) on real estate mortgage investment conduits (REMICs) and certain trusts.

Co-authors: Clay Littlefield, Ashley Menser.