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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

IRS publishes proposed guidance on foreign government income under Section 892

Alston & Bird LLP
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USA
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November 15 2011

The IRS has released proposed regulations relating to the taxation of the income of foreign governments from investments in the United States under Section 892

F reorganizations and double dummies

Alston & Bird LLP
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USA
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September 1 2012

LTR 201222014 ruled that persons contributing property to a new corporation in exchange for stock can form a control group with other persons contributing the stock of another corporation (target), and therefore enjoy Section 351 nonrecognition treatment

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

Reincorporation and the economic substance doctrine?

Alston & Bird LLP
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USA
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July 13 2011

Normally, achieving this restructuring would require Sub to distribute the business assets to Parent, which could create deferred intercompany gain that would be triggered into income if either the business or Sub left the group

Convertible preferred equity certificates

Alston & Bird LLP
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Luxembourg, USA
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July 13 2011

Instruments may be treated as debt for foreign income tax purposes but as equity or U.S. tax purposes

Top up options

Alston & Bird LLP
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USA
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January 11 2012

This article considers the intersection of the corporate law tool known as the “top up option” with the Internal Revenue Code’s section 338, which permits an election that can be favorable after certain corporate stock purchases

CFC’S Subpart F earnings not qualified dividends

Alston & Bird LLP
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USA
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December 15 2011

On December 7, 2011, The U.S. Tax Court ruled that inclusions in U.S. residents’ gross income that were required under the Subpart F provisions with respect to their controlled foreign corporation’s investments in U.S. property did not constitute qualified dividend income under Section 1(h) (11

Cross chain 351?

Alston & Bird LLP
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USA
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February 1 2012

LTR 201150021 is a surprising cross chain restructuring ruling that treats the transfer of the assets of one subsidiary of P to a subsidiary at the bottom of another chain of subsidiaries below P as a series of section 351 exchanges and a D reorganization at the bottom of the acquiring chain