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Results: 1-10 of 132

Better luck with economic substance doctrine John Hancock Life Insurance Co. v. Commissioner, 141 T.C. No. 1 (2013)

  • Alston & Bird LLP
  • -
  • USA
  • -
  • September 1 2013

John Hancock Life Insurance lost a recent decision in the U.S. Tax Court ruling on a combination of LILO and SILO transactions that were supposed to

Corporate letter rulings cut back

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 26 2013

Rev. Proc. 2013-32, issued on June 25, 2013, substantially restricts the scope of letter rulings that taxpayers can obtain from Chief Counsel

Federal tax advisory - eliminating a domestic sandwich LTR 201250004

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 1 2013

LTR 201250004 involved a domestic corporate Parent's purchase of a foreign group that had one domestic subsidiary. This is a common situation and Parent

Economic substance doctrine notice

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 5 2012

IRS Notice CC-2012-008 announces new Chief Counsel coordination procedures for assertion of the economic substance doctrine, which incorporate the LB&I Directives previously issued

Bankruptcy reorganization

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 28 2011

The taxpayer was able to convince the court that the creditors who got the stock in the reorganization were not the prior owners

Supreme Court limits exception to taxpayers’ lack of standing to dispute the expenditure of tax funds

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 1 2011

Federal tax cases, in contrast to state tax cases, rarely involve constitutional issues

Foreign F reorganizations

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 4 2011

U.S. Parent owned FS1, which owned DRE1, which owned DRE2. FS1 was domiciled in Country A but DRE1 and 2 were domiciled in Country B

Revised temporary regulations under Code sec. 7874 address surrogate foreign corporations

  • Alston & Bird LLP
  • -
  • USA
  • -
  • July 15 2009

Treasury and the Internal Revenue Service (IRS) have issued revised temporary regulations under Internal Revenue Code ("Code") section 7874 concerning the determination of whether a foreign corporation is treated as a surrogate foreign corporation

Spinoff can use corporate name

  • Alston & Bird LLP
  • -
  • USA
  • -
  • March 6 2012

LTR 201203004 rules favorably on a spinoff of Controlled to public shareholders in which Controlled will be allowed to use in its corporate name the trade name of Distributing, which will be licensed to Controlled by Distributing

Tax officer failed to write his own opinion

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 1 2012

The Tax Court applied the economic substance doctrine in Gerdau MacSteel, Inc., 139 TC No. 5 (August 30, 2012), and denied penalty relief in a liability management company “tax shelter” case because the company’s tax department failed to either obtain an outside opinion or write its own