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Results: 11-20 of 37
Mayo and Chevron
- Alston & Bird LLP
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- USA
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- February 1 2011
The Supreme Court rejected a challenge to Treasury's 2004 regulation defining a medical resident as a worker and not a student for purposes of FICA taxation
Substance over form?
- Alston & Bird LLP
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- USA
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- September 28 2011
Altria lost an appeal from an adverse jury verdict on its SILO and LILO transactions
Reincorporation and the economic substance doctrine?
- Alston & Bird LLP
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- USA
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- July 13 2011
Normally, achieving this restructuring would require Sub to distribute the business assets to Parent, which could create deferred intercompany gain that would be triggered into income if either the business or Sub left the group
Chevron deference and the Salman ranch
- Alston & Bird LLP
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- USA
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- June 1 2011
The same issue came before the Tax Court for later years
Foreign patent commercialization
- Alston & Bird LLP
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- USA
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- June 1 2011
Corp. A licensed certain technology to G (called Agreement A) in the past
Foreign F reorganizations
- Alston & Bird LLP
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- USA
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- June 4 2011
U.S. Parent owned FS1, which owned DRE1, which owned DRE2. FS1 was domiciled in Country A but DRE1 and 2 were domiciled in Country B
Earnings and profits reductions for 382 limited losses
- Alston & Bird LLP
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- USA
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- August 10 2011
Section 382 limits the amount of deduction allowed for net operating losses and built in losses subject to section 382(h
Anschutz Company
- Alston & Bird LLP
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- USA
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- February 13 2012
Just before New Year’s Eve 2011 the Tenth Circuit affirmed the Tax Court’s ruling against the taxpayer Anschutz Company in a case involving a variable prepaid forward contract
CFC’S Subpart F earnings not qualified dividends
- Alston & Bird LLP
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- USA
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- December 15 2011
On December 7, 2011, The U.S. Tax Court ruled that inclusions in U.S. residents’ gross income that were required under the Subpart F provisions with respect to their controlled foreign corporation’s investments in U.S. property did not constitute qualified dividend income under Section 1(h) (11
Quick peek discovery
- Alston & Bird LLP
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- USA
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- February 1 2012
A U.S. Court of Federal Claims judge has rejected some privilege claims and directed the taxpayer to allow the government lawyers a “quick peek” at other documents the taxpayer does not want to turn over in discovery
Current Search
- Jurisdiction - USA
- Workarea - Litigation
- Workarea - Corporate Tax
- Firm Name - Alston & Bird LLP
- Author - Jack Cummings