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Results: 1-10 of 122

Reorganization plan qualifies for bankruptcy exception to NOL limitation rules

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • 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

Lenders should consider suggesting bankruptcy to borrowers following the sale of delinquent taxes on a principal residence

  • Dykema Gossett PLLC
  • -
  • USA
  • -
  • January 31 2014

The Seventh Circuit Court of Appeals recently held that a plan under chapter 13 of the Bankruptcy Code can modify the rights of a purchaser of

That makes two for the FDIC: 11th Circuit Court of Appeals issues another precedential decision interpreting tax sharing agreements in bankruptcy, awards ownership of tax refund to FDIC

  • Kramer Levin Naftalis & Frankel LLP
  • -
  • USA
  • -
  • October 16 2013

Eleventh Circuit Court of Appeals has now issued two precedential opinions interpreting tax sharing agreements in bankruptcy in as many months. In

Low-income housing tax credits must be included in valuing section 506(a) collateral

  • Reed Smith LLP
  • -
  • USA
  • -
  • October 15 2012

In a case of first impression, the Sixth Circuit BAP held that, for purposes of valuing collateral under section 506(a) of the Bankruptcy Code, the availability of Low-Income Housing Tax Credits must be considered in valuing a creditor’s secured claim

IRS denies 501(c)(3) status to bankruptcy counseling agency

  • Venable LLP
  • -
  • USA
  • -
  • May 16 2011

On April 29, 2011, the Internal Revenue Service ("IRS") issued Private Letter Ruling ("PLR") 201117036 denying recognition of tax-exempt status under Section 501(c)(3) of the Internal Revenue Code ("Code") to a nonprofit credit counseling agency ("CCA") because its primary activity would have been the provision of pre-bankruptcy certification and post-bankruptcy counseling for fees

IRS issues guidance on outbound transfers of intangible property

  • Orrick Herrington & Sutcliffe LLP
  • -
  • USA
  • -
  • August 27 2012

In Notice 2012-39 (the “Notice”), the IRS issued guidance announcing its intention to issue regulations with respect to certain transfers of intangible property by a U.S. corporation to a foreign corporation in a reorganization described in section 361 of the Internal Revenue Code (the “Code”), citing significant policy concerns involving certain intellectual property transfers that permit U.S. persons to repatriate earnings without U.S. income taxation

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

When is a retirement account not a retirement account?

  • Ford & Harrison LLP
  • -
  • USA
  • -
  • June 16 2014

That's what the Supreme Court said last week in a case involving the Bankruptcy Code's exemption for "retirement funds." (The case is Clark v

Tax planning in a foreclosure

  • Dykema Gossett PLLC
  • -
  • USA
  • -
  • January 27 2009

With the country officially in a recession and the lack of available refinancing options continuing, more and more businesses are faced with the realities of foreclosure

BLG Monthly Update

  • Borden Ladner Gervais LLP
  • -
  • Argentina, Australia, Canada, United Kingdom, USA
  • -
  • December 19 2012

The BLG Monthly Update is a digest of recent developments in the law which Neil Guthrie, our National Director of Research, thinks you will find