We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
In cooperation with Association of Corporate Counsel
  Request new password

Search results

Order by most recent / most popular / relevance

Results: 1-10 of 138

Spin-offs become easier and easier

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

“Codifying the economic substance doctrine”

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

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

Ignore constitutional issues? Horne v. Department of Agriculture, 2013 U.S. LEXIS 4357 (2013)

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

Administrative agencies, including the IRS, commonly decline to consider challenges based on the Constitution or otherwise asserting that the law is

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

Obama tax officials

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 1 2009

President Obama has nominated Bill Wilkins to be IRS Chief Counsel and Beth Garrett to be Assistant Secretary of the Treasury for Tax Policy

Obama launches international tax reform proposals to heavy criticism

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

A VAT is in your future

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

Economic substance doctrine bill: unanswered questions

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