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Credit unions under attack

Alston & Bird LLP
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USA
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September 1 2009

We wrote in 2007 about a series of TAMs in which the IRS had asserted that various income items of exempt credit unions were taxable as unrelated business taxable incomemostly income from non-members and members not directly related to deposits of and lending to members

A VAT is in your future

Alston & Bird LLP
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USA
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June 1 2009

When the more prominent D.C. tax lobbyists begin to call for the adoption of a VAT to fill the seemingly bottomless deficit, the rest of us perhaps should sit up and take notice

White knight fees deductible

Alston & Bird LLP
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USA
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June 1 2009

The Tax Court has ruled that a corporation can deduct a $65 million termination fee it paid to a white knight to end its obligation to be acquired by the white knight and to permit it to accept a hostile offer that produced more value for its shareholders

Obama launches international tax reform proposals to heavy criticism

Alston & Bird LLP
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USA
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May 15 2009

On May 4, 2009, President Obama unveiled several major international tax proposals that are intended to correct perceived loopholes in current law

Spin-offs become easier and easier

Alston & Bird LLP
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USA
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February 2 2009

Recent government releases show that the section 355 spin-off continues to be a favored corporate transaction, despite Congress' efforts to restrict it in recent years

Economic substance doctrine bill: unanswered questions

Alston & Bird LLP
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USA
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July 1 2009

The bill aims to resolve or inform two, and only two, uncertainties that Congress believes the courts encounter when applying what the bill calls the “economic substance doctrine” to federal income tax disputes

“Codifying the economic substance doctrine”

Alston & Bird LLP
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USA
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April 1 2009

The Obama administration and Congressman Rangel have promised to "codify the economic substance doctrine," and thereby decrease the deficit by almost $5 billion over 10 years

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

Alston & Bird LLP
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USA
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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

Economic substance versus economic substance

Alston & Bird LLP
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USA
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April 1 2010

The Supreme Court recently declined to review a decision against a taxpayer that was based on a Code provision stating that section 1031 shall not apply to an exchange that is part of a transaction that was structured to avoid the purposes of section 1031(f