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Results: 1-10 of 341

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

  • Alston & Bird LLP
  • -
  • Australia, United Kingdom, USA
  • -
  • 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
  • -
  • 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

  • Alston & Bird LLP
  • -
  • USA
  • -
  • 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
  • -
  • 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

IRS issues regulations on outbound asset transfers

  • Alston & Bird LLP
  • -
  • USA
  • -
  • 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
  • -
  • USA
  • -
  • 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
  • -
  • 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

Gain on sale of partnership interest by nonresident alien taxable as effectively connected income

  • Alston & Bird LLP
  • -
  • USA
  • -
  • March 15 2013

In recently released Field Attorney Advice, the IRS reaffirmed its position that gain on the sale of a partnership interest by a nonresident alien

The constitutionality of tax reform

  • Alston & Bird LLP
  • -
  • 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

Sections 305 and 306 and tracking stock

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 25 2013

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

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