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Results: 1-8 of 8

Delinquent property tax collection: foreclosure may be vulnerable

  • Pepper Hamilton LLP
  • -
  • USA
  • -
  • September 25 2012

Wisconsin has a strict tax foreclosure procedure in which the tax authority effectively obtains the property without any public or competitive bidding in satisfaction of the delinquent tax bill

Valuing collateral: do low-income housing tax credits count?

  • Pepper Hamilton LLP
  • -
  • USA
  • -
  • November 27 2012

In valuing a bank claim secured by a low-income housing project for purposes of a plan of reorganization, should the remaining federal lowincome housing tax credits allocated to the project be taken into consideration?

Bankruptcy PLR with NOL preservation result

  • Pepper Hamilton LLP
  • -
  • USA
  • -
  • August 14 2012

Section 382 limits a loss corporations ability to use its Net Operating Losses (NOLs) carryforwards following an "ownership change."

Ad valorem property taxes: deadline for challenging in a bankruptcy

  • Pepper Hamilton LLP
  • -
  • USA
  • -
  • December 11 2012

Under Section 505(a)(1) of the Bankruptcy Code, generally a bankruptcy court may determine the amount or legality of any tax

Sixth Circuit holds that supplemental unemployment compensation benefits are not ‘wages’ subject to FICA taxation

  • Pepper Hamilton LLP
  • -
  • USA
  • -
  • September 10 2012

In an important recent decision, United States v Quality Stores, Inc., et al., in which Pepper represented the prevailing party, the U.S. Court of Appeals for the Sixth Circuit held that supplemental unemployment compensation benefits (SUB payments) paid by a bankrupt company to its former employees were not wages subject to taxation under the Federal Insurance Contributions Act (FICA

Losses and successive ownership changes at the forefront of recent IRS rulings

  • Pepper Hamilton LLP
  • -
  • USA
  • -
  • March 3 2011

The Internal Revenue Service (IRS) recently issued rulings regarding the availability of tax losses after a bankruptcy, the ability to take a loss under Sections 165(a) and 165(g), and the characterization of a loss after an ownership change

Proposed regulations regarding the deferred loss rules for controlled groups: not all good but not all bad

  • Pepper Hamilton LLP
  • -
  • USA
  • -
  • June 16 2011

On April 20, 2011, the IRS issued proposed regulations under Treas. Reg. 1.267(f)-1(c) (the Proposed Regulations), which will become effective after they are adopted as final regulations

Conversion of insolvent corporation into a tax partnership: IRS reaches favorable conclusions, but questions remain

  • Pepper Hamilton LLP
  • -
  • USA
  • -
  • November 21 2011

The "check-the-box" regulations permit certain eligible entities to elect their classification for U.S. tax purposes