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Reorganization plan qualifies for bankruptcy exception to NOL limitation rules

Morrison & Foerster LLP
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USA
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April 30 2013

In another recent private letter ruling, the IRS ruled that an ownership change pursuant to a bankruptcy reorganization plan qualified for an

Bankruptcy PLR with NOL preservation result

Pepper Hamilton LLP
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USA
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August 14 2012

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

You can’t hide from the IRS

Bryan Cave LLP
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USA
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May 2 2013

The general rule is that an IRA is exempt from the claims of creditors. Indeed, the Federal Bankruptcy Code provides in Sections 522(b)(3)(C) and

What matters: A review of 2011 and 2012

Kramer Levin Naftalis & Frankel LLP
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USA
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April 1 2013

As you know, the last two years have seen a somewhat improved, but by no means robust, business climate. At the same time, structural shifts in the

Cancellation of debt income realized by pass-through entities: some basic considerations

Seyfarth Shaw LLP
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USA
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July 6 2009

As a general rule, a debtor realizes taxable income upon the partial or total cancellation of its debt

EuroResource--deals and debt

Jones Day
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Argentina, Cyprus, France, United Kingdom, USA
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April 29 2013

On 29 March 2013, the Republic of Argentina proposed an alternative payment formula to the U.S. Court of Appeals for the Second Circuit that, if

IRS memorandum may offer taxpayer benefits relating to conversions of insolvent foreign corporations into partnerships

McDermott Will & Emery
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USA
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October 17 2011

The Internal Revenue Service’s recently issued general legal advice memorandum should provide beneficial results to certain taxpayers that use a check-the-box election to convert an insolvent foreign corporation into a partnership

Delinquent property tax collection: foreclosure may be vulnerable

Pepper Hamilton LLP
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USA
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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

International regulatory update 10-14 December 2012

Clifford Chance LLP
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European Union, Germany, Hong Kong, Italy, Spain, United Kingdom, USA
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December 17 2012

The European Council (Heads of State or Government) has published the conclusions from its meeting on 13 and 14 December 2012, at which it agreed on a roadmap for the completion of the Economic and Monetary Union

U.S. Bankruptcy Court puts the WHAM-O on Oregon's joint and several liability claim for corporate excise taxes on bankrupt WAMU parent

Sutherland Asbill & Brennan LLP
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USA
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March 21 2013

Oregon's $29 million corporate excise tax claim against the taxpayers' parent company was held to violate both the Due Process and Commerce Clauses

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Search results

Reorganization plan qualifies for bankruptcy exception to NOL limitation rules

Bankruptcy PLR with NOL preservation result

You can’t hide from the IRS

What matters: A review of 2011 and 2012

Cancellation of debt income realized by pass-through entities: some basic considerations

EuroResource--deals and debt

IRS memorandum may offer taxpayer benefits relating to conversions of insolvent foreign corporations into partnerships

Delinquent property tax collection: foreclosure may be vulnerable

International regulatory update 10-14 December 2012

U.S. Bankruptcy Court puts the WHAM-O on Oregon's joint and several liability claim for corporate excise taxes on bankrupt WAMU parent

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