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Results: 1-10 of 155

Limiting capitalization

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 13 2013

LTR 201319009 seems to be an odd ruling, because the taxpayer sought a ruling that it had to capitalize certain costs of an acquisition through use

Proposed legislation and pending corporate guidance

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 1 2013

At a recent D.C Bar Tax Section Corporate Tax Committee meeting, panelistsincluding a Treasury representativediscussed some of the Administration’s

How hedge funds and private equity firms can manage Foreign Corrupt Practices Act risks

  • Alston & Bird LLP
  • -
  • USA
  • -
  • March 27 2013

In recent years, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have aggressively investigated and enforced both

World’s longest letter ruling

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 1 2012

LTR 201240017 is the world’s longest letter ruling, 111 pages in PDF format

CERT regulation proposed

  • Alston & Bird LLP
  • -
  • USA
  • -
  • September 17 2012

Twenty three years after it was enacted in 1989, the Treasury issued proposed regulations interpreting section 172(h), the corporate equity reduction transaction (CERT) loss carryback disallowance rule dating from the heyday of the leveraged buyouts

F reorganizations and double dummies

  • Alston & Bird LLP
  • -
  • USA
  • -
  • September 1 2012

LTR 201222014 ruled that persons contributing property to a new corporation in exchange for stock can form a control group with other persons contributing the stock of another corporation (target), and therefore enjoy Section 351 nonrecognition treatment

Reverse acquisitions and tax insurance

  • Alston & Bird LLP
  • -
  • USA
  • -
  • July 25 2012

LTR 201228002 involves a plain vanilla group structure change in a consolidated group owned by a foreign parent

Avoiding the section 338 consistency rules

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 9 2012

LTRS 201213013 and 201214012 are the same ruling, evidently issued to a buyer and a seller, in the common scenario where the seller consolidated group wants to sell subsidiary stock and the buyer wants to buy assets and obtain a cost basis; both taxpayers got what they wanted, including placing the target corporation into the buying consolidated group, without having a qualified stock purchase and thereby avoiding the consistency rules

Spinoff can use corporate name

  • Alston & Bird LLP
  • -
  • USA
  • -
  • March 6 2012

LTR 201203004 rules favorably on a spinoff of Controlled to public shareholders in which Controlled will be allowed to use in its corporate name the trade name of Distributing, which will be licensed to Controlled by Distributing

Monetizing losses

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 23 2012

LTR 201203004 illustrates how to split up a public company’s two businesses, while monetizing the tax losses of one of the businesses so that it can have a better chance to survive

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