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Distribution of foreign company stock in outbound reorganization was indirect disposition of intangible property subject to Section 367(d) Disposition Rule

Alston & Bird LLP
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USA
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June 15 2013

In Chief Counsel Advice (CCA) 201321018, the IRS concluded that a U.S. target corporation's Section 361(c) distribution of stock of a foreign

REIT conversions

Alston & Bird LLP
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USA
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June 7 2013

LTR 201314002 has caused quite a buzz in the investment community. Stock pickers want to know how far the envelope can be pushed on the definition of

PPL and a wealth tax

Alston & Bird LLP
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USA
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June 3 2013

On May 20, 2013, the Supreme Court of the United States decided PPL Corporation and Subsidiaries v. Commissioner, 569 U.S. __ (2013). This was the

The United States, Australia and the United Kingdom gang up on international tax evasion

Alston & Bird LLP
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Australia, United Kingdom, USA
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May 15 2013

In a news release on May 9, 2013, the tax authorities of the United States, Australia and the United Kingdom announced a plan to share tax

Limiting capitalization

Alston & Bird LLP
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USA
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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

Alston & Bird LLP
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USA
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May 1 2013

At a recent D.C Bar Tax Section Corporate Tax Committee meeting, panelistsincluding a Treasury representativediscussed some of the Administration’s

The Supreme Court, federal taxation and the constitution

Alston & Bird LLP
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USA
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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

IRS issues regulations on outbound asset transfers

Alston & Bird LLP
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USA
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April 15 2013

The IRS recently issued final, temporary and proposed regulations concerning transfers of assets by U.S. corporations to foreign corporations in

Several economic development bills pass as the Georgia General Assembly wraps up its 2013 Regular Session

Alston & Bird LLP
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USA
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April 8 2013

The Georgia General Assembly's 2013 Regular Session wrapped up on March 28, 2013, but not before a number of bills that should have the effect of

Supreme Court to review economic substance case

Alston & Bird LLP
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USA
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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

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Search results

Distribution of foreign company stock in outbound reorganization was indirect disposition of intangible property subject to Section 367(d) Disposition Rule

REIT conversions

PPL and a wealth tax

The United States, Australia and the United Kingdom gang up on international tax evasion

Limiting capitalization

Proposed legislation and pending corporate guidance

The Supreme Court, federal taxation and the constitution

IRS issues regulations on outbound asset transfers

Several economic development bills pass as the Georgia General Assembly wraps up its 2013 Regular Session

Supreme Court to review economic substance case

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