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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

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

GLAM 2012-007

Alston & Bird LLP
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USA
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December 1 2012

The IRS Chief Counsel advises the field in this general legal advice memorandum (GLAM) that a subsidiary does not enter a corporate group when the common parent buys the stock needed for affiliation for a note carrying below-market interest so as to compel the seller to exercise its right to take the stock back after two years

STARS transaction rejected

Alston & Bird LLP
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USA
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February 20 2013

On Feb. 11, 2013, a regular Tax Court opinion was issued in a case that the opinion said was of first impression, ruling against Bank of New York

Section 305(b)(2) warrants

Alston & Bird LLP
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USA
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April 2 2012

LTR 201213011 rules that a domestic corporation can generate a section 301 distribution to its shareholder(s), possibly for the purpose of creating capital gain, possibly to allow use of an expiring capital loss of the shareholder

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

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

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

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

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