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Limiting capitalization

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

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

In my recently published book, The Supreme Court, Federal Taxation and the Constitution, I review several constitutional issues that could impact the

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 Administration has indicated that it will pursue fundamental tax reform; leaders on the Hill have also indicated interest in doing so. Therefore

LTR 201308001 rules on sections 305 and 306 are bread and butter subchapter C provisions that were designed for "tax shelters" that are so quaint and

On Feb. 11, 2013, a regular Tax Court opinion was issued in a case that the opinion said was of first impression, ruling against Bank of New York

In the late 20th century, the IRS made a combination of unrelated decisions resulting in a proliferation of upstream C reorganizations. First was the

LPCiminelli Interests, Inc. v. United States, 110 AFTR 2d 2012-6631 (W.D. N.Y. 2012) ruled that a consolidated group did not have to amend its

In generic legal advice released in November 2012 (AM 2012-009), the Chief Counsel's Office, applying the economic substance doctrine, disregarded a